|
33.
|
About how many NEW Phase II 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") |
|
|
a. 2004: | CTRs |
|
|
b. 2005: | CTRs |
|
|
c. 2006: | CTRs |
|
34.
|
What was the TOTAL number of Phase II 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") |
|
|
a. 2004: | exceptions |
|
|
b. 2005: | exceptions |
|
|
c. 2006: | exceptions |
|
35.
|
What key factors, contributed to any changes in the number of Phase II exemptions your institution filed in calendar years 2004-2006? |
|
36.
|
On average, how many minutes per Phase II exemption does it take your financial institution to complete each of the following steps? (Enter 0 if not applicable) |
|
|
a. Determine customer eligibility for Phase II exemption | minutes |
|
|
b. Fill out the exemption form | minutes |
|
|
c. Compliance officer or approving official reviews the exemption form | minutes |
|
|
d. File the exemption form with FinCEN or Treasury | minutes |
|
|
e. Complete the annual review of eligibility | minutes |
|
|
f. Complete the biennial recertification of eligibility | minutes |
|
|
g. Other steps your institution requires | minutes |
|
|
h. If you mentioned other steps, please describe them. |
|
37.
|
At your institution are the following parts of the Phase II 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 II 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 | ||||||
|
|
f. Complete the biennial recertification of eligibility | ||||||
|
38.
|
Do you have any comments you'd like to make about your institution's Phase II exemption filing process; for example, software used to help with the automation, additional steps that you take, etc.? |
|
39.
|
In 2006, how important were each of the following factors in your financial institution's decision to exempt a customer eligible for the Phase II exemption? |
| Very great importance | Great importance | Moderate importance | Some importance | Little or no importance | Don't know | ||
|---|---|---|---|---|---|---|---|
|
|
a. Nature of client base provided opportunities to exempt Phase II customers | ||||||
|
|
b. Ease of determining a customer's Phase II exemption eligibility | ||||||
|
|
c. Guidance in the BSA examination manual was clear for Phase II exemptions | ||||||
|
|
d. Cost effectiveness of filing exemptions rather than CTRs for eligible customers | ||||||
|
|
e. Opportunity to file fewer CTRs | ||||||
|
|
f. Availability of automation to identify eligible Phase II customers | ||||||
|
|
g. Minimal concern about compliance risk (that is, that examiners would find a basis for a violation) | ||||||
|
|
h. Regulator recommended we apply Phase II exemption | ||||||
|
|
i. Other factor - Please describe below. | ||||||
|
|
j. If you mentioned another factor, please describe it. |
|
40.
|
How simple or complex is it for your financial institution to file Phase II exemptions? | ||
| 1. | |||
| 2. | |||
| 3. | |||
| 4. | |||
| 5. | |||
| 6. | |||
|
41.
|
In 2006, did your institution exempt most or all customers that you believe were eligible for the Phase II exemption? | ||
| 1. | (Click to go to Question 45.) | ||
| 2. | |||
| 3. | |||
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