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#1933867 - 06/18/14 10:36 PM Mergers-Refile Exemptions-Amended CTR's
Joined: Sep 2005
Posts: 73
Looking for help on what to do after a merger:

If the other institution had accounts that they had filed a Designation of Exemption would we need to send in an new DOEP or can we leave as is.

Also if during a review (of course after the merger was complete) we find errors on CTR's should we send amended CTR's if so how far back should we go?


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#1933878 - 06/19/14 11:52 AM Re: Mergers-Refile Exemptions-Amended CTR's UTBPMOM
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Previous thread

As for amending CTRs, there is no stop sign based on a specific time frame. If it's incorrect, then correct it. At some point, however, I would stop reviewing them...
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1933943 - 06/19/14 02:41 PM Re: Mergers-Refile Exemptions-Amended CTR's UTBPMOM
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,598
Cape Cod
This should be self-evident, but I think it bears repeating. Although you do "inherit" the acquired bank's DOEPs, as the acquiring bank you aren't presumed to share the same appetite for risk or even the same exempt-person policy the acquired bank had. It would not be at all unusual for an acquiring bank to pick and choose which of the acquired bank's exempt persons it will continue with or to exempt additional acquired accounts that the acquired bank had not chosen to exempt.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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