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Designation of Exempt Persons- Bank Merger

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One holding company owned two banks that operated individually with separate taxpayer identification numbers and routing numbers. The banks recently merged, becoming one bank and retaining the larger banks-name, TIN and routing #, however, the smaller bank's routing # is still in existence. Do we need to fill a new DOEP's for the smaller bank's customers under the new banks information?

The "surviving" bank should file new DOEPs for the exempt persons that will be carried over from the smaller (acquired) bank, omitting any that the surviving bank decides it does not wish to have exempted. In doing the "transfer" of exempt persons from the smaller bank, the acquiring bank gets the benefit of the smaller bank's transaction history so that there's no need for a "waiting period" before filing.Remember, however, that the acquiring bank is responsible for ensuring that the persons it designates are actually eligible, so it would be wise to carefully review the exemption files that the acquired bank maintained until now.

First published on 1/2/12

First published on 01/02/2012

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