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Documenting a BSA Exemption

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Question: 
I have some questions regarding exempting customers. When you are initially exempting a person, what kind of documentation should be put in a file for the auditor's review, and would I use the same documentation for the biennial review?
Answer: 

One of the best things you can do is create an Exemption Checklist and place a copy in each file folder.

The “Initial Exemption Checklist” could include items such as:

  • Has the customer been with the bank at least 12 months
  • Has the customer had greater than 8 CTR transactions in the last 12 months
  • Copy of the TDF form
  • Has the account been reviewed for suspicious activity, if so what were the findings
  • Articles of Incorporation (to include signers)
  • Explanation of the exemptions primary business

The biennial checklist can be very similar to the Initial Checklist and could include some additional questions that might impact its exemption status:

  • Are there any new accounts added or deleted, if so what type of accounts are they
  • Has there been any change in ownership or Employer Identification Number (EIN)

First published on BankersOnline.com 12/6/04

First published on 12/06/2004

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