I know this has been asked in this forum before and I have searched but could not find it. We have purchased a bank. When I go and review for BSA, am I correct that any customer on their exempt list can remain on the exempt list as long as I review the activity and they qualify for exempt status. Also on Phase II, should I file another DOEP?

Thanks for your advice.

Recent thread

To both questions, yes. You want to have any required DOEP filings under your bank's record at FinCEN from the day the acquisition is finalized. And when you review activity of Phase II exempt customers, you can include the activity "bought" with the acquisition.

Thanks to both Ken and John. I thought that was the case but wanted to be certain.

Oops. Thank Ken for linking to the recent thread. I could not locate it. I guess I was doing something wrong. I can get forgetful at times.

It's all good, Crash. And if you hadn't posted your question this time, I never would have seen Ken's response in the other thread. I haven't seen "brogans" used in years, but I'm not surprised to see it used by my Kentucky sage and friend.

I would like to revive this thread! We are the acquirED bank, not the acquirER. I have been asked by the acquiring institution to determine the process for "exempting" our exempted customers, that is, whether DOEP's can be immediately filed for those under the acquirER institution's credentials. Although what is stated in this thread is logical, I would like to ask whether there is written guidance. I have searched the BSA regulation and FinCEN's website, did not find anything.