There is no conclusion that can be drawn from the fact that something was not criticized in prior independent or regulatory examinations. Question 17
indicates a non bank financial institution can be recognized as an exempt person if the revenues from that activity do not exceed 50% of the gross. You do not indicate that there is a second source of revenue. If this activity is their sole source of revenue, exemption is not
Kosher or not, exempting a non bank financial institution confuses examiners and prompts calls to the regional office.