We have an existing Phase II corporation (restauraunt-pancake house) that has been exempt with us for years. A routine annual review was conducted at the end of last year, and the corporation was still eligible for exemption. Recently, the corporation added a DBA to their name and are doing business as a bar that sells lottery, food and alcohol-same EIN. What type of supporting documentation is required right now, if any, or is waiting until the next annual review at the end of the year acceptable? I reviewed several guidance documents, but could not find a question/answer that addressed this particular scenario. Thank you.

I'll start by assuming that the lottery sales aren't significant enough to worry about the business being ineligible. Since this business is only adding a line of business in a separate location, it's still the same customer, and the exemption should extend to all of its locations. I don't believe you have any work to do with respect to the exemption other than satisfy yourself that the business has the requisite licenses to operate the new "division."

Of course the new line of business is one that may cause you to increase your due diligence for things like MSB activity, and it will bring a new type of cash flow that won't look like the restaurant business. Those are things you will need to adjust to, but I don't think they affect the exemption.