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14.
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About how many NEW Phase I exemptions did your financial institution file in each of the following calendar years? (If you did not file any exemptions in a particular year enter "0") |
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a. 2004: | CTRs |
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b. 2005: | CTRs |
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c. 2006: | CTRs |
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15.
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What was the TOTAL number of Phase I exemptions your financial institution reviewed in each of the following calendar years? (If you did not file any exemptions in a particular year enter "0") |
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a. 2004: | exceptions |
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b. 2005: | exceptions |
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c. 2006: | exceptions |
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16.
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What key factors, contributed to any changes in the number of Phase I exemptions your institution filed in calendar years 2004-2006? |
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17.
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On average, how many minutes per Phase I exemption does it take your financial institution to complete each of the following steps? (Enter 0 if not applicable) |
|
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a. Determine customer eligibility for a Phase I exemption | minutes |
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b. Fill out the exemption form | minutes |
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c. Exemption form reviewed by compliance officer or approving official | minutes |
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d. File the exemption form with FinCEN or Treasury | minutes |
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e. Complete the annual review of eligibility | minutes |
|
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f. Other steps your institution requires | minutes |
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g. If you mentioned other steps, please describe them. |
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18.
|
At your institution are the following parts of the Phase I exemption filing process done manually or are they automated? |
| Fully manual | Mostly manual | Equally manual and automated | Mostly automated | Fully automated | Not applicable | ||
|---|---|---|---|---|---|---|---|
|
|
a. Determine customer eligibility for Phase I exemption | ||||||
|
|
b. Fill out the exemption form | ||||||
|
|
c. Compliance officer or approving official reviews the exemption form | ||||||
|
|
d. File the exemption form with FinCEN or Treasury | ||||||
|
|
e. Complete the annual review of eligibility | ||||||
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|
f. Other processes | ||||||
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g. If you mentioned other processes, please describe them. |
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19.
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Do you have any comments you'd like to make about your institution's Phase I exemption filing process; for example, software used to help with the automation, additional steps that you take, etc.? |
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20.
|
In 2006, how important were each of the following factors in your financial institution's decision to exempt a customer eligible for the Phase I exemption? |
| Very great importance | Great importance | Moderate importance | Some importance | Little or no importance | Don't know | ||
|---|---|---|---|---|---|---|---|
|
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a. Nature of client base provided opportunities to exempt Phase I customers | ||||||
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b. Ease of determining a customer's Phase I exemption eligibility | ||||||
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c. Guidance in the BSA examination manual was clear for Phase I exemptions | ||||||
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d. Cost effectiveness of filing exemptions rather than CTRs for eligible customers | ||||||
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e. Opportunity to file fewer CTRs | ||||||
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f. Availability of automation to identify eligible Phase I customers | ||||||
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g. Minimal concern about compliance risk (that is, that examiners would find a basis for a violation) | ||||||
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h. Regulator recommended your institution apply Phase I exemption | ||||||
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i. Other factor - Please describe below. | ||||||
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j. If you mentioned another factor, please describe it. |
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21.
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How simple or complex is it for your financial institution to file Phase I exemptions? | ||
| 1. | |||
| 2. | |||
| 3. | |||
| 4. | |||
| 5. | |||
| 6. | |||
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22.
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In 2006, did your institution exempt most or all customers that you believed were eligible for the Phase I exemption? | ||
| 1. | (Click to go to Question 26.) | ||
| 2. | |||
| 3. | |||
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