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Phase 1 Exemptions- Statement of Condition

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A recent BSA review suggested that an annual review for Phase I exemptions needed a documented statement of condition or something similar to satisfy the BSA review requirements. Any suggestions on a simplified way to locate the information?

Who did this review? If this was a hired consultant, I would suggest looking for a new one. The only requirement would have been to validate that the bank was still a bank. That could be done through a variety of sources, such as the FDIC institution search website here. Also, these rules have now changed and you should review this document as depository institutions will no longer be required to review annually or make a designation of exempt person (DOEP) filing for customers who are other depository institutions, U.S. or state governments or entities acting with governmental authority. Read more about this here.

First published on 2/02/09

First published on 02/02/2009

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