We had a similar situation a couple of years ago (customer exempted as LTD and changed to LLP). I'm not sure how much of a difference there is between the two, but we just made a change and submitted the biennial renewal since there hadn't been any change in ownership. We've had Safety and Soundess exams since then and no comments regarding that process. Of course, I realize that it doesn't necessarily mean it was the right way to handle the issue. Perhaps a call to your BSA Rep at IRS DCC, FinCEN would be best??