Skip to content
BOL Conferences
Thread Options
#1299265 - 12/04/09 07:55 PM Help! Changing Exemption
ApacheBelle72 Offline
Platinum Poster
Joined: Sep 2006
Posts: 652
We have a company (been with us and exempt for a long time. Now they have changed their name, EIN, and are now a Listed Company. I know we need to amend their exemption, but how would "they" know who it is if the EIN has changed. I'm stumped on this one. Thanks for any input.

Return to Top
BSA/AML/CIP/OFAC Forum
#1299321 - 12/04/09 08:38 PM Re: Help! Changing Exemption ApacheBelle72
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
It sounds to me that you are now dealing with a different entity, which means that you must treat it as a new customer and file a new exemption. Because it is a listed company, you won't need to wait before filing a new Form 110 Designation of Exempt Person.

You can let the old exemption lapse without filing a termination form.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1299326 - 12/04/09 08:42 PM Re: Help! Changing Exemption John Burnett
ApacheBelle72 Offline
Platinum Poster
Joined: Sep 2006
Posts: 652
John, Thank you for your quick response!

Return to Top

Moderator:  Andy_Z