You do not need to do biennial renewals on Phase I exemptions. You do, however, have to review the exemptions at least annually to verify that they are still appropriate. For example, you need to ensure that the listed company is still listed and that the financial institution is still operating under the same name (hasn't changed names, or been acquired).
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8