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