This is my first review of DEP forms. The person that filled out the form entered the renewal date in box 11 instead of the "effective date of exemption". I have asked them to send me the initial date, but all they have is the month and year. Will it be acceptable to not have a specific date? Thanks,

If FinCEN has told you that all they have regarding the initial date of exemption is 6/01 and neither of you can determine the exact day, then I would use 6/15/01 on subsequent forms. That's not the "right" answer, just the only one that seems reasonable...

I think that I am a little confused. Are you saying that you have no records of your initial exemption filings? These are generally reviewed closely by our regulators so we keep copies. I believe that you can also request the information directly from the IRS.

It wasn't FinCEN that told me they didn't know the date, it was the prior BSA Officer. Sorry for the confusion.

I would think that there should be a copy in a file somewhere of the initial designation with a date on it. I keep a separate file on each of my exempt persons and include all the forms pertaining to that entity as well as supporting documentation and reviews. Hopefully there is a file somewhere that would provide this information.

Do you keep your records over 5 years?

Thanks,

Yes. As far as the Exempt Person File - my understanding is that records are to be retained for five years after the exemption expires or is revoked so they will be in my file for awhile. That is why I would think that the information should be available somewhere - especially since the exemption is still valid.