Make sure you retain the documentation for the review. We've heard from several bankers that they were criticized in their Exam Reports, for not being able to prove that the review was done.
Also, if the review primarily relies on a listing of the customers' deposits, you will likely be cited for a violation of the BSA. (We've heard this complaint from several bankers. Most systems do not separate the cash and non-cash portions of a customer's deposit; they only record the total deposited amount. The BSA requires that you review the cash portion of each deposit.)
We have a system that can help with this. It also generates the exemption forms and helps you keep track of when biennial filings are due. Please give me a call if you'd like more information, or to see a demo via the Internet.
Wayne Barnett, President
Wayne Barnett Softwarewww.barnettsoftware.com