When I submit a Designation of Exempt Persons form via the BSA E-Filing system, will I receive a final confirmation that the DEP has been approved? My transmission has been accepted, but I have not received anything further. I have an inquiry in with the BSA folks, but they are slow in responding. Thanks all.

"will I receive a final confirmation that the DEP has been approved?"

No one approves exemptions. Making sure that the customer is eligible is totally up to the Bank.

You will only receive an acknowledgement that the e-filing was accepted and you will also get a DCN (document control number) which you will need if you ever revoke this particular exemption. As Randy explained, this is not meant to be an approval of the approprietness of your exemption, only that it was received.

Thanks all.

As to the statement about the DCN, I have never heard of any required action when revoking an exemption. That is, besides starting to file CTRs again. Can you please elaborate on why I would need the DCN and any action that is required. Thank you!

There is no requirement that you revoke your exemption filing. The DCN is simply an indicator that the filing has been received and recorded. I suppose that, if you ever were challenged on whether you filed an exemption (by an examiner, for instance), you could simply provide the DCN as evidence.

The Document Control Number (DCN) is the unique number assigned to each BSA filing. When filing an “Initial Designation” through BSA E-Filing you will get this number. This number is required when amending/revoking an exemption through BSA E-Filing system. In Part I on FinCEN Form 110, when checking box c (Exemption amended) or box d (exemption revoked), if you don't provide the DCN it will not allow you to precede.

True, Bee Cee. However, you are under no requirement to send in a form to revoke a designation. Instead, you can simply start filing CTRs. Filing the CTRs does not cause FinCEN or the IRS Data Center to flag the designation as revoked, but you still need to file a new DEP if you later determine that the customer can again be exempted.

From the instructions to the August 2005 version of the DOEP:

A bank may, but is not required to, use this form to notify the Treasury that the bank has revoked the designation of a customer as an exempt person.

If you revoke it, apparently the e-filing mechanism requires you to jump through some hoops. However, you are not required to revoke it.

My understanding is that the next iteration of the DOEP, the one reflecting the amendments to the exemption process that took effect in January, 2009, will not mention revocation at all.