If Phase II, and the non-listed business engages in ineligible business (for example lottery) how do you confirm that is it less than 50% of the gross revenue if there is no lending relationship with financials?

I use a form for the customer to certify the percentage of gross revenues derived from that ineligible activity.
The businesses that I have exempt are grocery stores or gas stations who sell lottery tickets. They have "lottery accounts" set up separate from their general store account. I look at the activity in both accounts to determine if the form they completed "makes sense" according to their account activity.

Might want to review this also:

http://www.fincen.gov/statutes_regs/guidance/pdf/fin-2009-g001.pdf