Our annual exemption review procedures have included among other things a request of each exempt customer to complete a form identifying each store location depositing with us and asking for a detailed breakdown of the type of activity conducted at each location; e.g., sale of money orders, check cashing, etc. including whether or not the activity exceeds the MSB registration threshold. Based on comments from examiners, we have done more than most in this regard as far as documentation.

We currently have a large customer that owns number convenience stores with gas stations. The number of stores increased substantially since last year and the customer is balking at providing this "per store" information because they don't have the manpower to provide the information and no other bank requests this information. To remove this customer from our exempt list will cause untold pain given the large number of transactions on a daily basis with the multiple locations.

I've said all that to ask if anyone would be willing to share the procedures they use to document their annual exemption review of "non-listed" exemptions. I am FDIC regulated and am particularly interested in what has worked for other such banks. Thanks

we were just examined by the OCC in one of the most intense exams in my 33 years

we go by the main office and get that information. roll up finanacial info, etc and not worry about each store.

now if you are dealing with an NBFI that is different in that you have to be aware of their agents, etc at those locations. but they are required to do that by law

not required for an exemption

Thanks. Do you have a checklist you use for your annual exemption reviews?

Go to Bankers Tools and look for Brenda C's exemption review worksheet. Best I've seen.