If you've identified a bona fide Phase I exempt customer, determine whether a Form 110 needs to be filed to declare that exemption to FinCEN. If it's a Reserve Bank, a bank, government unit or agency, or an entity exercising government powers (103.22(d)(2)(i, ii or iii), no Form 110 is needed, just note the change in status to Phase I in your records and start treating the customer as a Phase I exempt customer.
If the customer is a listed company under 103.22(d)(2)(iv), file the Form 110, note the change in status in your files, and proceed to treat the company as Phase 1 exempt.
There is no need to revoke the old Phase II exemption.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8