Exempt Customers and Annual Review: CRCM Exam Question Answer | ABA Provider

Exempt Customers and Annual Review

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Question

First National Bank has several exempt customers.

" Alpha is an exempt person because its stock is listed on a major stock exchange.

" Beta is an exempt person because it meets the nonlisted customer requirements.

" Zeta is exempt because it is a payroll customer.

For which customer(s) must the bank conduct an annual review to determine its continuing eligibility to be exempt from CTR filings?

Answers

Explanations

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A. B. C. D.

D

Under the Bank Secrecy Act (BSA) and its implementing regulations, financial institutions are required to file Currency Transaction Reports (CTRs) for certain cash transactions above a threshold amount. However, certain customers are exempt from CTR filings if they meet certain requirements.

In this scenario, First National Bank has three exempt customers - Alpha, Beta, and Zeta. Alpha is exempt because its stock is listed on a major stock exchange, Beta is exempt because it meets the nonlisted customer requirements, and Zeta is exempt because it is a payroll customer.

According to the BSA and its regulations, financial institutions must conduct an annual review of each exempt customer to determine if they continue to meet the requirements for exemption. This review ensures that the bank is still justified in exempting the customer from CTR filings.

Therefore, the bank must conduct an annual review to determine the continuing eligibility for exemption from CTR filings for all three customers: Alpha, Beta, and Zeta. So the correct answer to the question is D. Beta and Zeta.