Q: When filing the DEP form for biennial renewals of CTR exemptions for non-listed businesses and payroll customers, what date should be entered as the “Effective date of the exemption” in Part II box 11?
A: A bank must report the biennial renewal of CTR exemptions for eligible non-listed businesses and payroll customers by completing and filing a DEP form every two years (calendar years) by March 15. See 31 CFR § 103.22 (d)(5)(ii). For biennial renewals, the date entered in Part II box 11 as the “Effective date of the exemption” should be the same date the depository institution used in this box when the initial designation was made utilizing the reformed CTR exemption regulations. (10/2001)
This FAQ was obtained from FinCEN’s website, in the section for Answers to Frequently Asked BSA Questions, which may be found here: