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#2054466 - 12/16/15 06:10 PM Acquired Designated Exempt Person
KSciabica Offline
New Poster
Joined: Sep 2015
Posts: 6
Hello, does anyone have information regarding taking over a DOEP? We recently acquired a bank and have attempted to reach FinCEN but could not get through.

Our thought is to amend the existing exemption and switch it to our bank.

Any help is appreciated.

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BSA/AML/CIP/OFAC Forum
#2054470 - 12/16/15 06:24 PM Re: Acquired Designated Exempt Person KSciabica
BSAChick Offline
Member
Joined: Oct 2005
Posts: 94
Illinois
We were instructed to amend them.
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#2054602 - 12/16/15 11:11 PM Re: Acquired Designated Exempt Person KSciabica
KSciabica Offline
New Poster
Joined: Sep 2015
Posts: 6
Thank you, we can not find guidance anywhere.

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#2054618 - 12/17/15 11:57 AM Re: Acquired Designated Exempt Person KSciabica
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
When you acquire a bank you acquire their BSA compliance effort, warts, exemptions, everything. If they are right, they're right. If they are wrong,.. There is no printed direction that they must be amended. However, if you do not amend them they will not be tied to your bank when examiners request a print out of your exempt customers and you will have to explain the discrepancy.

Amending them is fine and avoids a worthless conversation.

My suggestion is you do them over from scratch just to make certain they are right and that you have all the documentation you need.
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