Answer:
The requirement for an annual review applies to both Phase I and Phase II exempt persons:
(4) Annual review. The information supporting each designation of an exempt person, and the application to each account of an exempt person described in paragraphs (d)(2)(vi) or (d)(2)(vii) of this section of the monitoring system required to be maintained by paragraph (d)(9)(ii) of this section, must be reviewed and verified at least once each year.
First published on BankersOnline.com 5/16/05
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