We have added a local government client, the first one in a few years. Do I still need to file a DOEP for this customer to be Phase I exempt? I've read section 1020.315 several times which might be part of the problem. Thanks

https://www.bankersonline.com/regulations/31-1020-315

Refer to (c)(2)(i)(B)

Thanks. I got confused at first in all the sub-sections.