Good Morning,

I am performing my annual review for DOEP. I have a Phase II customer whose status is now listed as "Inactive - Dissolved (Administrative)" on our state's Secretary of State website (which is what we use to determine if Phase II customers are still authorized to do business). Supposedly, they are working to get that reinstated, but my deadline for the review is today. I'm not sure how to handle this. If I give them time, then my review is untimely. If I revoke the exemption, can I wait a few days for them to get it corrected, then file a new DOEP and not file any CTRs because the DOEP is retroactive for 30 days? Or do I revoke the exemption, file any CTRs that result, then file a new DOEP when they get it fixed? It feels like the second option will look odd on FinCEN's side if they get a new DOEP for a customer that their files show as already exempt. Does marking the exemption amended box fix that problem? I am completely turned around on this.

Revoke. File. Reinstate when they qualify.

Would I mark the new DOEP form as an Initial Designation or as an Exemption Amended in that case?

It would be a new initial designation.

Thanks so much for the help!