The bank I work for recently purchased another bank. How do I handle their BSA exemptions? Do I just fill out A "Designation of Exempt Person" form and check the box for an amended exemption, and enter the information for my bank in Part III? What do I do for the "Effective Date of the Exemption" - use the date we purchased the other bank or use the date the other bank originally exempted the customer? They recently filed their Biennial Updates so I'm assuming I can ignore that part of the form. All help is appreciated!

I would contact the the Department of Treasury and get a written response or at least verbal direction. Be sure to document who you speak to!

I agree with Jeff. BSA was a very hot item with our last exam. They were nit-picking everything. Since all of the new rules are now in stone, the examiners are going to be looking at how you complied.

I would definately get a written response from your institution's regulators.

I guess it wouldn't hurt to contact FinCEN, but don't be surprised if staff tells you to do nothing until the next biennial review. When you merged the other bank, you became one. If FinCEN and federal law enforcement agents care about your exempt customer, they can still contact you at the address the former bank listed--it just isn't a head office any more.