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#496369 - 02/09/06 08:21 PM exemption for transactions of bank subsidiaries
nemsi Offline
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Joined: Nov 2005
Posts: 383
We are a parent bank holding company with 3 bank subsidiaries. If cash is bought/sold between 2 of our subsidiary banks do we need to complete DOEP/FinCEN Form 110 for each subsidiary bank? Does it matter that it is a subsidiary or do we treat it as all other bank designations. I would appreciate your thoughts on this.

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BSA/AML/CIP/OFAC Forum
#496370 - 02/09/06 11:34 PM Re: exemption for transactions of bank subsidiaries
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
I would file a Form 110. I have never seen an exemption for transactions with affiliates of the same holding company.
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#496371 - 02/10/06 01:45 PM Re: exemption for transactions of bank subsidiaries
nemsi Offline
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Joined: Nov 2005
Posts: 383
Thanks rlcarey.

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