Exempt - not exempt - now exempt again - New DEP?

A customer was exempt. The restaurant burnt down. We never revoked the exemption because they were going to rebuild. It took them over 12 months to rebuild. When they reopened we filed CTR's until they became eligible again. Do we file another DEP or is the previous one still good?

i think that when you filed the recent CTRs that would have automatically revoked the previous exemption. You should file a new DOEP with the current exemption date.

I agree with nemsi's assessment.

Thank you for the feedback

Filing CTRs on an exempt customer does not revoke the exemption - if anyone has any guidance that says otherwise, I would like to see it.

If the Bank considered the exemption revoked, then I would file a new DOEP.

Oops!Thanks Randy. I feel confident that if you've never seen any guidance on this it does not exist. I had interpreted what i had read concerning revoking an exemption to indicate that form 110 was not required to revoke an exemption- the bank could just start filing form 104. I assumed that an entity is either exempt or not exempt. Not good to assume. It is good to have gurus!

If you were to assert that the exemption is still valid, someone is going to ask you for a copy of the required annual review...your best position is that the exemption was revoked.