Can we send in our biennial renewal forms that are due March 15, 2005 now or do we have to wait until 3/15/05 so that the date of signature reflects 3/15?

There is no alternative to the biennial renewal process that would allow early or late renewal. The biennial renewal must be done on March 15th of the second calendar year after the exemptions are granted.

Sorry, still confused - instructions say: As provided for by 31 CFR 103.22(d)(5)(ii), the exemption status of all eligible non-listed businesses must be updated once every two years, by March 15. This update is a biennial renewal... Customer effective exemption date was 01/29/2003 therefore I need to submit biennial renewal this year. Do I wait and mail the form on 3/15/2005 and then mail it on 3/15 every other year?

"By March 15" means "on or before" March 15. It's like filing your taxes. You can do it at any time after January 1, but not after April 15 (without an extension).

You just don't get an extension for filing your biennial reviews.

Do I have to file renewals on correspondent banks?

No. Banks are Phase I exempted. Phase I exempt persons do not require renewals. They do require that you verify their qualification for the Phase I exemption at least annually (is the bank still in business?)

Yes. How do I verify their qualification? Should I have something in file. And we have begun dealing with a new bank. Do I need to file something for them?
Thanks.

Thanks Jokerman.