Can someone out there please settle an argument for me regarding ineligible businesses for Phase II exemption? The reg states that a business engaged primarily in "the practice of law, accountancy, or medicine" is ineligible. Does the practice of medicine include a hospital?

Thanks for your responses.

I wouldn't want to argue the point with my regulator without a FinCEN opinion, or other regulatory guidance, in my hand that they are eligible.

There are no previously published resources of the kind Brenda describes, but I agree with her. Doctors and the business entities they own practice medicine, hospitals do not.

Obviously, if the hospital is eligible for exemption under Phase I, the issue goes away.