4.2 Life Cycle of an Exemption

The following sections describe the life cycle of an Exemption.

Open

When a user creates a new Exemption or re-opens an Exemption, the status of that Exemption is changed to Open. All Exemptions must be created manually.

Closed

A user can close an Exemption if its status is changed to Open or Re-Open from Revoked, Rejected, or Closed status.

Pending Review

The status of an Exemption is changed to Pending Review in the following scenarios:

  • When a user takes a Submit for approval action or any other action taken along with Submit for approval
  • When a supervisor submits for Exemption approval while creating new Exemption/Reopening rejected/Revoked/Closed Exemptions

In-review

The status of an Exemption changes to In-review when a Supervisor views an Exemption in Pending Review status.

Rejected

The status of an Exemption can be changed to Rejected when Exemptions are denied. This status is considered as inactive status of Exemption.

Reopen

The status of an Exemption can be changed to Reopen when its in Rejected, Revoked, or Closed status.

Rework

The status of an exemption can be changed to Rework if it is determined that the exemption is causing a failure in the filing of the DOEP e-file. If the DOEP Status reflects an e-file failure ("DOEP Filed - E-file Rejected", "Amended DOEP Filed - E-File Rejected", "Revoked DOEP Filed - E-File Rejected") and the Exemption Status is "Exempt" then the user will have the option to select the Rework action. When the exemption is pushed to Rework status the user can then regenerate the DOEP e-file without the erroneous exemption. Exemptions placed in a status of Rework will have the DOEP status set to Null. At this point, the exemption can be put back through the normal flow to be corrected and approved and sent back to the DOEP e-filing flow.

Exempt

The status of an Exemption can be changed to Exempt when a Supervisor approves an Exemption. An Exemption can move to Exempt status in the following cases:

  • When a newly created Exemption is approved by the supervisor to be Exempt.
  • When an existing Exemption goes through the yearly system-triggered or user-submitted recertification process and is Recertified.
  • When Revoked/Rejected Exemptions are Reopened and Exempted again.
  • When Rejected/Closed Exemptions are reopened and Exempted.

Recertify

The status of an Exemption can be changed to Recertify in the following scenarios:

  • Upon an Exemption record moving to Exempt status, CTR applies an Initiate Recertification Date that is the current day + 320 calendar days (45 days prior to the yearly review date).

    Note:

    The Initiate Recertification Date range is configurable by clients and can be set for something other than 45 days. Clients can specify which class of exemption are not subject to FinCEN recertification requirements and are not expected to follow a yearly recertification process (such as, Phase I - Bank, Phase I - Federal, State or Local Gov Agency/Dept and Phase I - Entity Exercising Govt'l Authority w/in US). When specified, exemptions which are categorized as such will not receive an Initiate Recertification date. As a result such exemptions will never automatically enter the recertification workflow.

  • When a user recertifies (Approve – Recertify) the status returns to an exempt status and the process repeats (initiate recertification date is reset).
  • When a user does not recertify (Rejected – Recertify) the Exemption status moves to Revoked and initiates recertification and expiration dates are cleared.

Reassign

An Exemption can be reassigned in the following statuses:

  • Open
  • Pending Review
  • In-review
  • Pending Recertify Review
  • In Recertify Review
  • Pending Revoke Review
  • In Revoke Review
  • Reopened
  • Reassigned
  • Recertify

Reassign is not possible on an Exemption in the following statuses:

  • Exempt
  • Revoked
  • Closed
  • Rejected

Filing the Exemptions

This section details the various DOEP and Exemptions statuses when the Exemptions are Approved or Revoked to support DOEP Filing:

  • DOEP Not Required: This action button is activated once the Exemption is approved and the DOEP status is NULL and the Exemption class is any of the following:

  • Phase I - Bank
  • Phase I - Federal, State, or Local Gov Agency/Dept
  • Phase I - Entity Exercising Govt'l Authority w/in US
    • Generate DOEP: This action button is activated once the Exemption is approved, and the DOEP is NULL and the Exemption class is any of the following:
  • Phase I - NYSE/ASE Listed; NASDAQ Mkt Sec Listed
  • Phase I - Subsidiary of NYSE/ASE Listed; NASDAQ Mkt Sec Listed
  • Phase II - Payroll Customer
  • Phase II – Eligible Non-Listed Business

On successful action, the DOEP status is changed to Exempt – Ready for DOEP Filing.

  • Amend DOEP: This action button is activated once the Exemption is Exempt and the DOEP status is any of the following:
    • DOEP Filed - Success
    • Amended DOEP Filed - Success
    • DOEP Filed - Success w/Errors
    • Amended DOEP Filed - Success w/Errors
    • Revoked DOEP Filed - Success w/Errors
    • DOEP Filed - Rejected
    • Amended DOEP Filed - Rejected
    • Revoked DOEP Filed - Rejected

On successful action, the DOEP status is changed to Exempt – Amended Ready for DOEP Filing.

  • Revoke DOEP: This action button is activated once the Exemption is Revoked and the DOEP status is any of the following:
    • DOEP Filed - Success
    • Amended DOEP Filed - Success
    • DOEP Filed - Success w/Errors
    • Amended DOEP Filed - Success w/Errors
    • DOEP Filed – Rejected
    • Amended DOEP Filed – Rejected

On successful action, the DOEP status is changed to Exempt – Revoked Ready for DOEP Filing.

Revoked

The status of an Exemption can be changed to Revoked in the following scenarios:

  • Revoke action can be taken on Exemption which is in Exempt status. However, this action results in Pending Revoke Review status. Once a supervisor approves the Revoke, (Approve – Revoke), the Exemption moves to Revoked status, if the supervisor rejects (Reject – Revoke) the Exemptions status changes to Exempt.
  • Submit for Revoke action can be taken on Exemption which is in Recertify status. However, this action results in Pending Recertify Review status. Once the supervisor approves the Reject

Recertify, the Exemption moves to Revoked status. If the supervisor approves the Approve Recertify,the Exemption is extended for the next one year from the date of Approve Recertify action and Exemption status changes to Exempt.

  • Exemptions that are in Revoked status can be reopened to reinstate the Exemption.
  • CTR expires the Exemptions on the date of expiry irrespective of the status, however the Exemption status remains.
  • When the Exemptions that are in Pending Recertify Review, In Recertify Review, Pending Revoke Review, and In Revoke Review status pass the expiry date, CTR revokes the Exemption by clearing the exempt date from the Exemption without changing the status.

In Revoke Review

The status of an Exemption can be changed to In-Revoke Review in the following scenarios:

  • When a supervisor views an Exemption that is in the status of Pending Revoke Review, the status changes to In Revoke Review. The possible actions on In Revoke Review state are Approve Revoke or Reject Revoke.
  • The Expire Date is not cleared on the Exemption until an Exemption is in In Revoke Review status. Clearing of Expire Date on an Exempt Entity depends on the supervisor’s action. If a supervisor takes a Reject Revoke action, then the Expire Date stays on the Exempt entity as is. If a supervisor takes an Approve Revoke action, then the Expire Date is cleared from the Exemption entity immediately.

In Recertify Review

The status of an Exemption can be changed to In-Recertify Review in the following scenarios:

  • When a supervisor views an Exemption that is in Pending Recertify Review, the status changes to In Recertify Review.
  • A supervisor can take Approve Recertify action which changes the Exemption status to Exempt and can extend the expiry date to next one year from the date of Approve Recertify action.

Pending Revoke Review

The status of an Exemption can be changed to Pending Revoke Review when Submit for Revoke Exemption action is taken on Exemption which is in Exempt status.

Pending Recertify Review

The status of an Exemption can be changed to Pending Recertify Review when a user takes the Submit for Renewal Approval action on the Exemption which is in Recertify status.

E-files of the respective purged exemptions will be purged only if all the exemptions for which the e-file was generated are purged. If even a single exemption in the e-file does not match the lookback period criteria and is present in the application then the e-file will not be purged.