Here's the scenario:
ABC Foods (a restaurant) has been an exempt customer for several years. We originally exempted it as an eligible non-listed business. During a due diligence review we learned that the franchisee, QLC Restaurants Inc., is a listed company. It appears that the name on the original exemption should have been QLC Restaurants Inc. dba ABC Foods and noted as Phase I.

Would you agree that we should amend the current exemption to show the name QLC Restaurants Inc. dba ABC Foods and that it is Phase I? There is no change in the other information.
Thanks

I would amend it and also change the account titling, signature cards, etc that your bank has on file so that everything reflects the proper legal name.

Just be very certain that you are looking at the right player. In other words, if your customer is the local franchisee and it's the franchisor that is listed, you can't consider your customer eligible for Phase I treatment.

Thanks much.