We have aquired three new branches from another bank. In regards to BSA, do we need to exempt businesses that were exempted with the previous bank or could they be considered grandfathered? If we do need to exempt, do they have to have an account with us for 12 months?

We did not get clear guidance on the details of the exemption. I would file an exemption form for each customer revising the name of the bank and continue the exemptions. I would file these forms only after I conduct my own due diligence review to make sure I want to continue the exemptions.