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Proposed Renewal of Exempt Person Form

FinCEN has issued a proposal to renew the Designation of Exempt Person Form. Comments are due by April 22, 2002. It appears in Vol 67 of the Federal Register, No. 34 at page 7736. You can also find the proposal on FinCEN's website.

This proposal is part of a routine update for information collection forms. Federal agencies are required, by the Paperwork Reduction Act, to review their data collection procedures every three years. This includes a review of the process and of the form used to collect the information. The form cannot be reissued without approval from OMB.

The result, as in this case, is a comment period that isn't really going to result in much change. It is an opportunity to put any concerns or ideas on the official record.

The most interesting aspect of commenting is to give the agency and OMB information about the amount of time necessary to prepare and complete the report. FinCEN has published its time estimates: 10 minutes to prepare and file the response, 1 hour to prepare and maintain recordkeeping for the response. If you think this is realistic, sit back and have a cup of coffee. But if you believe you put more time into the exemption process, now is the time to say so - and to explain why.

Copyright © 2002 Compliance Action. Originally appeared in Compliance Action, Vol. 7, No. 3, 3/02

First published on 03/01/2002

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