We are undergoing a BSA exam from the FDIC and I am being told that we have to file a revocation with FinCEN if a customer is no longer exempt. I was under the impression that this was optional! Help!!
THANKS!

From the back of the DOEP form:

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 your examiner cannot read or is not persuaded by the things he reads, call the Helpline and let him talk to them.

Make sure your policy doesn't state that you require it to be filed. It maybe optional by FinCEN, but you are also bound by your bank's policy and procedures.

THANK YOU SO MUCH!!

Ok...so I don't want to rock the boat but I am being told to file a revokation right now for a customer I revoked in 2010. Also, it is not in our policy to file these. Rock on?

Why placate someone who's ignorant? From the August, 2009 Guidance FinCEN issued on the revised exemption process:

Question: If a bank ceases to treat a customer as exempt, and begins or intends to begin filing CTRs on that customer for the next reportable transaction, must the bank formally revoke the exemption by filing the DOEP form and selecting the “exemption revoked” box?

Answer: Banks have never been required to formally revoke an exemption using the DOEP form. Generally, examiners or other users of BSA data would be able to rely on a pattern of reporting to know that a customer is no longer being treated as exempt. For purposes of clarity or creating internal documentation, however, many banks voluntarily revoke exemptions using the DOEP form. For example, if during its annual review of an exempt non-listed business customer a bank discovers that the customer conducted no reportable transactions in the previous year, the bank could no longer treat that customer as exempt. If the exemption is not formally revoked using the DOEP form and the customer continues the pattern of not conducting reportable transactions, a law enforcement agent investigating the company would likely conclude incorrectly from the lack of CTR filings that the customer is still being treated as exempt. While revoking an exemption in such instances may benefit both the filing bank and users of BSA data, banks may choose to do so entirely on a voluntary basis. (Emphasis supplied)

If you want to appear to be flexible, show him the resources above and tell him you will do it, but you don't expect to read about it in the written report of examination.