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#1452490 - 10/06/10 06:58 PM BSA Exemption
RBanker Offline
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RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
Yay - Congratulations to us - we're a de novo and I'm preparing to file for my first exemption for a non-listed business, a Phase II Exemption.
I've read through 31 CFR 103.22 to try and determine what, if any, supporting documentation needs to be submitted with my FinCEN Form 110 and I can't find anything - looking for any help someone might be able to give me.

Thanks
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BSA/AML/CIP/OFAC Forum
#1452498 - 10/06/10 07:03 PM Re: BSA Exemption RBanker
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
I don't believe that any documentation has to be submitted with the FinCEN Form 110. However, with your copy of the form, keep a screen shot or other document that can attest to the fact that the transaction account has been maintained at the bank for at least 2 months and that it has had frequent transactions in currency with the bank in the excess of $10,000 (usu. 5 or more within the past 12 months). You most likely already have the requisite business documents on file. These will serve as verfification that the account met the conditions for exemption.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1452592 - 10/06/10 07:58 PM Re: BSA Exemption Doug Hendrickson
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,458
Somewhere
You don't need to submit anything, just as Doug has said, keep a file for each customer containing all documentation proving their eligibility. Examiners will review this during an exam.

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#1452656 - 10/06/10 08:50 PM Re: BSA Exemption P*Q
RBanker Offline
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RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
Thanks all.....
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My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.

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