Would anyone be willing to share their procedures for exempting "non-listed" businesses under the Bank Secrecy Act Phase II rules? I am interested in what types of due diligence are being performed on customers that the bank wants to exempt under Phase II and what types of documentation are being gathered and maintained for regulatory review. Thanks to all that respond.

Jeff, I have a form I would be willing to share with you. This form is designed for our account officers to use in documenting eligibility for exemption under Phase II rules. Each officer is asked to conduct on-site visit of business prior to exemption and then periodically based upon nature of business activities. Visits to high risk businesses (whether exempted or not) are conducted more often.

I am in the process of revising our procedures to require account officers to submit evidence of registration for businesses operating as MSBs.

As BSA Compliance Officer, I review submitted information and make the final determination as to whether the business will be exempted.

We obtain a new form to document retail business activities prior to biennial renewal, and more often for higher risk businesses or if we note a change in pattern or nature of transactions.

Brenda, I noticed that your profile does not include an email address. Would you be interested in sharing that form with all readers? (trust me, you will have multiple requests. This is the easiest way to respond) Mary Beth, can you get a copy of this form and post in here? Thanks.

I would be happy to post it, Brenda, if you would send it to me. Email it to mbguard@bankersonline.com

Brenda has shared her form and it looks like it would be a very effective tool.

You can find it now in Banker Tools.

Thanks, Brenda!