Archive Links

Consumer Archive
CU System Archive
Market Archive
Products Archive
Washington Archive

News Now

Washington
Compliance Determining ineligible revenues for CTR exemptions
WASHINGTON (5/27/09)—It is not always easy to determine if a business member can qualify for a Phase II Currency Transaction Report (CTR) exemption when that member engages some “ineligible” business activities. But according to Financial Crimes Enforcement Agency guidance (FIN-2009-G001), a business “may qualify for an exemption as a non-listed business provided that no more than 50% of its annual gross revenues are derived from one or more ineligible business activities.” For instance, imagine a situation where a federal credit union has a business account related to a small “full-service” real estate company that handles real estate sale/purchase transactions, does title searches, provides real estate brokerage services, and so on. The business engages in a number of large cash transactions during each month that require currency transaction reporting. To determine if the business member qualifies for a CTR exemption, the credit union must make a “reasonable determination” that the member derives no more than 50% of its annual gross revenues from ineligible business activities. To make this determination, the credit union could take into account member certifications regarding annual gross revenues, review the business’ audited financial statements, or review the business’ most recent tax returns. If the business' gross annual revenues derived from the real estate brokerage business activity is less than half the total, then the business should qualify for the exemption. For more on this and other compliance topics, visit the Credit Union National Association’s Compliance Challenge using the link below.
Other Resources

RSS print
News Now LiveWire
Even 1 step makes a difference in preparing for disasters #creditunions #NewsNow http://t.co/eFUmMJnIwA
10 hours ago
From today's @USATODAY front page, a shout out to #CreditUnions courtesy of @CUNA http://t.co/881vLPeECN
11 hours ago
Happy anniversary to the ATM! 45 years of self-service cash HT @GOBankingRates http://t.co/ycsm3GFwk5
13 hours ago
.@USATODAY print edition features #creditunion membership march to #100mm. Zoom in on lower left hand corner #NewsNow http://t.co/Xv8fyX7ces
13 hours ago
No special assessment for ASI member #creditunions in 2014. See #NewsNow http://t.co/NwL9eJwbiQ
14 hours ago