Question: When filing a DEP Biennial Renewal what date goes in #11, the original effective date of the exemption or the effective date of the biennial renewal?
We're just not clear on this!

Thanks,
Vicki

The orginal effective date of the exemption. That's what we are using.

That's what we've been entering there, but after thinking about it, I wasn't sure whether that was correct. Thanks for answering! I appreciate it!!

Vicki

It's amazing that the instructions for this form are so unhelpful. It's as if someone came up with the form and decided that the instructions should say "You figure it out"!

I agree -- use the date the original exemption was approved (from your first filing of the form) under Phase II rules.

I am taking the time to agree only because the form does not answer the question and because I have seen examiners equally confused on this point.

You are filing a renewal. The original effective date of the exemption may have been some years prior.

Question 16 on FinCENs FAQs addresses the exemption date question.
http://www.fincen.gov/reg_faqs.html

Thank you, Brenda!

Thanks everyone! I really appreciate your help!!