We purchased another bank in December of 2003. This bank had filed an exemption on their customer on 11/1/02 and conducted a review on 3/1/03. We recognized the exemption. On 1/12/04 we sent in an amendment to the US Treasury changing the bank name to our own, but I did not mark the box as biennial renewal at this time along with the exemption amended box. Am I out of compliance for not sending in the biennial renewal in 2004? Can I send in the biennial renewal this year? What can I do? Thanks for any help!

I've heard rumor that if you check two boxes on the form, FinCEN will only process the first one, whichever it may be. You may want to contact the FinCEN regulatory help line at 800-949-2732. They are very helpful.

Thanks for the information - I will give them a call.