You could not add any exemptions under the so-called "old rule" after 10/21/1998. And all old-rule exemptions had to be converted to Phase II by July 1, 2000, or dropped. Reference is to §103.22
(d)(11) of the Treasury's Recordkeeping and Reporting rules (a/k/a BSA regulations).
So, it appears that you might have had an exemption in place under the old rules through June 30, 2000 (if the exemptions was created before 10/21/1998).
I hope this helps you out.