BSA Question

We have as a customer a large supermarket chain. Their stock is traded on the American Stock Exchange and we have filed the appropriate documentation to exempt them from CTR reporting. Recently, however, they were purchased by a Belgian Company - Delhaize America, which is also a publicly traded company on the New York Stock Exchange. Do I need to file a new exemption form with change of control information? And, if so, how do I complete it. The company based in our state, still considers itself a separate business that is part of a larger company - still uses its own tax ID number etc., but no longer trades its own stock. Any help you could give me would be much appreciated. Thanks.

Sue Norton
Opinions are mine and not necessarily those of my employer.

I suggest you refile, and this time characterize the company as a "listed company subsidiary." Before you do so, get together your documentation of that fact. First, identify the parent company's stock symbol and pull up something on the Internet that shows them trading on a national exchange. Print it and keep it.

Then, take a look at the SEC's EDGAR site for filings that show that your supermarket chain was purchased by the European company and their stock de-registered. Print that, too, for the file. That will demonstrate their subsidiary status.

Periodically, check to make sure there are no filings indicating that the parent sells the chain.