Skip to content

BHC Merging Banks -Refiling Current Exempt Persons

Answered by: 

Question: 
My holding company is getting ready to merge our three banks. Do we need to refile the current exempt persons from CTR reporting under our new EIN and routing numbers? Can this be handled at time of review?
Answer: 

When you collapse multiple charters into one, new DEP forms must be filed for all impacted exempt customers. The old bank EIN numbers will no longer apply and will need to be up-dated with the new EIN information. After the collapse has been completed, file a new Designation of Exempt Person form no later than 30 calendar days following an entity’s reportable transaction in currency. Waiting to make these changes (e.g. during an annual review) may result in a violation, because you did not file the proper forms to notify the government and validate the exemption status.

First published on BankersOnline.com 1/30/06

First published on 01/30/2006

Filed under: 
Filed under security as: 

Search Topics