DOEP for Acquired Institution

We recently acquired a bank and now have a list of their exempt customers (there are only two). Going into this I was prepared to file a new DOEP for these but in looking at the names, they are also customers of my bank and we too have already exempted them.

I'm guessing I don't have to file a DOEP now since we already have filed in these two businesses with a DOEP form - seems obvious now that I type it out. With so many things to consider for an acquisition, my mind is spinning.

Looking for a confirmation.

I wouldn't if you already have them exempt under the surviving institution.

I recently went through a merger where my institution was acquired. The acquiring bank in the past has always amended the DOEPs for institutions they have purchased to reflect the new current bank name. However, when I spoke to FinCEN they stated that DOEPs cease to exist for acquired institutions as of the legal merger date. Based on that information we filed new DOEPs in the current bank name. Even though I have spoken directly to FinCEN there appears to be a difference of opinion. Has anyone else had experience in this area? I know the bank will be looking to acquire other institutions so I would love to have some feedback even though I stand by what I was told by FinCEN.

Thanks!

Well, if an examiner requests your DEOP list from FinCEN during a BSA exam, how are the ones filed by the now extinct organization going to get into your bank records? Are you going to find something specific on the subject, I doubt it. Does it make total sense - yes.