The DOEP form
is hopelessly out of date as revisions taking effect in January 2009 were never reflected on the form or its instructions other than the notation in Part V.
At one time FinCEN published the following as an amendment to the instructions: To assist depository institutions in completing the DOEP, FinCEN Form 110, FinCEN is providing the following guidance for items affected by this final rule.
 Depository institutions should disregard any references to biennial renewals that appear on the face of FinCEN Form 110 (specifically, Part I, Item 1b, ‘‘Biennial renewal’’; Part II, Item 11; Part III, Item 19, second sentence; and Part V), as well as in the instructions to the form (specifically in the second paragraph under the heading ‘‘When and where to file’’; the second sentence under the heading ‘‘Specific Instructions’’ that begins, ‘‘Additionally, with regard to non-listed businesses. * * *’’); and the instruction to Item 11 under the heading ‘‘Exempt Person Information.’’
 Depository institutions should disregard Part II, Item 10a, ‘‘Bank’’ and ‘‘Government agency/Government authority.’’
Specific questions may be directed to the FinCEN Helpdesk by calling 800-949-2732, and selecting option 3.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.