If a bank is in the process of purchasing a bank. If the bank we about to acquire has exempt customers can they stay on the exempt list or do we take them off the exempt list until they qualify again.

I do want to review their activity to be certain they still qualify but if they still qualify can they be added to our list.

Thanks

The acquisition includes the history of all of the acquired bank's accounts. So, when you review each of the acquired exemptions, you can file a DOEP on each you approve based on its history with the acquired bank (along with the other qualifying characteristics). No need to wait for a qualifying two-month period.

John, Thanks. I was hoping that would be how you handle that situation. Again thanks for your help.

Agreed. As long as the acquired bank did everything correctly, you stand in their shoes. If they did something incorrectly, those brogans are yours too.

I suggest you do your own review of eligibility as of the current date...

That is my plan. If after a review is done on the customer and I do not feel comfortable giving them an exempt status I am not. Thanks for your comments. They are appreciated.

This should be self-evident, but I think it bears repeating. Although you do "inherit" the acquired bank's DOEPs, as the acquiring bank you aren't presumed to share the same appetite for risk or even the same exempt-person policy the acquired bank had. It would not be at all unusual for an acquiring bank to pick and choose which of the acquired bank's exempt persons it will continue with or to exempt additional acquired accounts that the acquired bank had not chosen to exempt.