FinCEN DOEP Electronic Filing Requirements.

FinCENDOEPElectronicFilingRequirements.pdf

Transactions of Exempt Persons Regulations, and FinCEN Form 110-Designation of Exempt Persons (DOEP) Report

FinCEN DOEP Electronic Filing Requirements.

OMB: 1506-0012

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Financial Crimes Enforcement Network

FinCEN Designation of Exempt Person
(FinCEN Form 110) Electronic Filing
Requirements
Release Date March 2015 – Version 1.2

DEPARTMENT OF THE TREASURY

Financial Crimes Enforcement Network (FinCEN)

Financial Crimes Enforcement Network

Table of Contents
Revision History

iii

Purpose

Electronic Filing

File Organization

Record Layouts

Transmitter (1A) Record – Required

Filer Information (2A) Record – Required

Affiliated Bank Information (2B) Record

Exempt Person Information (3A) Record – Required

Filer Information Summary (9B) Record – Required

File Summary (9Z) Record – Required

Acknowledgement Record Formats

Acknowledgement Transmitter (1A) Record

Acknowledgement Filer Information (2A) Record

Acknowledgement Affiliated Bank Information (2B) Record

Acknowledgement Exempt Person Information (3A) Record

Acknowledgement Trailer for Transmitter (9Z) Record

Attachment A – Error Code List

Attachment B – Error Correction Instructions

Attachment C – Electronic Filing Instructions

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Revision History
Version
Number

Date

Reason for Change

1.0

09/19/12

General Updates:







Updates electronic specification document title from “Bank
Secrecy Act Designation of Exempt Person (FinCEN Form 110)
Electronic Filing Requirements” (see new title on cover page) and
replaces “BSA DOEP” with “FinCEN DOEP” throughout the
document.
Replaces all references to “filing organization” with “filing
institution” throughout the document.
Acknowledgement File Format
Updates the acknowledgement file format to include User Field
values from incoming records.
FinCEN DOEP “report”
Replaces the reference to the FinCEN DOEP as a “form” with
“report” throughout the document.

Updates to File Organization:


Filer Information (2A) Record
Replaces “filing organization” with “filing institution” in the first
sentence.

Updates to Record Layout:




Transmitter ZIP/Postal Code (as well as Items 23/11)
Updates the Description and Remarks to include “or four nines”
in the following statement: “A nine-digit ZIP Code cannot end
with four zeros or four nines.”
Transmitter Country
Updates the Description and Remarks by adding the sentence
“See General Instructions 5 in Attachment C for information
about the country codes to be entered.”
Coverage Beginning Date/Coverage Ending Date
Updates the Description and Remarks by replacing “original
exemption” with “Effective Date of Exemption” in the first
sentence for each field.
Effective Date of Exemption (Item 2)
Updates the Description and Remarks by replacing “following
day’s date after the date of the last transaction to be exempted”
with “date of the day following the date of the last exempted
transaction” in the last sentence.
Exempt person is entity
Updates the Description and Remarks by replacing “Enter “X” if
the exempt person is an entity” with “Enter “X” if the exempt
person is an entity and space fill the “First Name, “Middle
Name,” and “Name Suffix” fields.”
Middle Name/Name Suffix (Item 5)

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Version
Number

Date

Reason for Change



Updates the Description and Remarks by replacing “Space-fill if
no entry” with “Space-fill if no entry or if “Exempt person is
entity” contains “X.”
E-mail address (Item 14) and Phone Number (Item 15)
Updates the Field Name by removing “(If available)”for
clarification purposes.
Items 26/27/29
Updates the Description and Remarks by removing “Space-fill if
no entry.”
BSA Identifier/Document Control Number
Updates the Field Name and Description and Remarks by
replacing “BSAI” with “BSA ID.”

Updates to Attachment A – Error Code List


Errors Codes
Adds the error code F24 “Number of forms reported on the batch
form does not match the computed count of the forms found in
the file” to the list of error codes.

Attachment B – Error Correction Instructions


Error Categories
Replaces the statement “fatal errors that result” with “format
errors that may result” in the first sentence of the section.

Attachment C – Electronic Filing Instruction




General Instructions (7. Name Editing Instructions)
Updates “7. Name Editing Instructions” to match the instructions
in the FinCEN SAR and FinCEN CTR.
Item Instructions (Item 18 – EIN)
Updates “Item 18—EIN” instructions to “Enter the bank’s
Employer Identification Number (EIN).”
Item Instructions (Item 25 – Affiliated banks
Adds “some or” in the following sentence: “A parent bank
holding company or one of its bank subsidiaries may make the
designation of exempt person on behalf of some or all bank
subsidiaries of the holding company so long as the designation
lists each bank subsidiary that will treat the customer as an
exempt person.”
Secure Data Transfer Mode Users
Updates the instructions to include a section describing the
naming convention information related to SDTM/System to
System filers.

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Version
Number

Date

Reason for Change

1.1

09/27/14

Attachment C – Electronic Filing Instructions


1.2

03/01/2015

General Instructions (5. Addresses):
Removed “Note: The ISO 3166-1 country list includes entries for
all U.S. territories. Do not use these U.S. territory entries, which
match the U.S. Postal Service abbreviations required in state
fields, in any country field.” Added “Note: The ISO 3166-1
country list contains entries for all U.S. territories, including the
United States Minor Outlying Islands. Do not use these U.S.
territory entries, which may match the U.S. Postal Service
abbreviations required in state fields, in any country field.”

Updates to Attachment C – Electronic Filing Instructions
 General Instructions (5. Addresses):
Removed “Note: The ISO 3166-1 country list contains entries for all U.S.
territories, including the United States Minor Outlying Islands. Do not
use these U.S. territory entries, which may match the U.S. Postal Service
abbreviations required in state fields, in any country field.”
This change was made as the discrete (online) reports were updated to
include the following entries in Country fields:
American Samoa, (AS)
Guam, (GU)
Marshall Islands (the), (MH)
Micronesia (the Federated States of), (FM)
Northern Mariana Islands (the), (MP)
Palau, (PW)
Puerto Rico, (PR)
Virgin Islands (U.S.), (VI)
These values can now be used in Country fields to adhere to the ISO
3166-1 standard.

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Purpose
The purpose of this document is to provide the requirements and conditions for electronically
filing the Bank Secrecy Act Designation of Exempt Person (DOEP) report (FinCEN Form 110).
Electronic filing of this report will be through the BSA E‐Filing System operated by the
Financial Crimes Enforcement Network (FinCEN). For more information on the BSA E‐Filing
System and to register, please go to http://bsaefiling.fincen.treas.gov. This document should be
used in conjunction with the “General Specifications for Electronic Filing of Bank Secrecy Act
(BSA) Reports” (General Specifications) available at http://www.fincen.gov/forms/files/efiling_GENspecs.pdf. It is recommended that you refer to the General Specifications first, and
then the specific information contained in this document. If the General Specifications conflict
with any specific requirement found in this document, the specific requirement should be
followed. Additional instructions concerning the data to be entered in the electronic file are
found in Attachment C – Electronic Filing Instructions.

Electronic Filing
The BSA E‐Filing System Batch File Testing Procedures are detailed in a separate document that
can be accessed on the BSA E‐Filing System web site at http://bsaefiling.fincen.treas.gov under
Quick Links. For purposes of this document, the filer is the organization responsible for filing
the FinCEN Form 110 (DOEP) and the transmitter is the organization responsible for preparing
the electronic files. The filer and transmitter may be the same or different organizations. Filers
are required to retain a copy of the DOEP data and all original supporting documentation or
business record equivalent for five years from the date of the report. All supporting
documentation must be made available to appropriate authorities upon request.

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File Organization
The following data controls must be followed or the DOEP electronic file will be rejected. The
data records must be in the following sequence:
Transmitter (1A) Record – Required
There can only be one of these record types and it must be the first record on the file.
Filer Information (2A) Record – Required
There must be one of these record types for each filing institution on the file. This record type
immediately precedes all records related to the filer.
Affiliated Bank Information (2B) Record
One or more of these record types may follow a 2A Record when the designation is being made
for one or more affiliated banks. Filers are permitted to associate up to 99 2B records for a single
exemption report. Multiple 2B records must be grouped together prior to the associated Exempt
Person Information (3A) Record(s).
Exempt Person Information (3A) Record – Required
There can only be one of these record types for each exempt person reported on the file. Filers
are permitted to associate multiple 3A records with a single 2B record or a set of 2B records—
assuming the affiliated bank(s) is(are) the same for all associated 3A records that follow.
Filer Information Summary (9B) Record – Required
There must be one of these record types for each 2A record reported on the file.
File Summary (9Z) Record – Required
There must be one of these record types on the file and it must be the last record.

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Record Layouts
Transmitter (1A) Record – Required
The first record on each file must be the Transmitter (1A) Record, which will contain
information identifying the batch file transmitter (person or organization handling the data
accumulation and formatting). There will be only one transmitter record on each electronic file.
All data elements for this record are required.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

3-152

Transmitter Name

150

REQUIRED. Enter the full name of the individual or
organization that is transmitting the exemptions in this file. Left
justify and space-fill the entry.

153-252

Transmitter Address

100

REQUIRED. Enter the street address of the transmitter. Left
justify and space-fill the entry.

253-302

Transmitter City

REQUIRED. Enter the city of the transmitter. Left justify and
space-fill the entry.

303-305

Transmitter State

REQUIRED. Enter the state code of the transmitter if the
“Transmitter Country” is “CA,” “MX,” or “US.” Space-fill if
“Transmitter Country” contains a country code other than
“CA,” “MX,” or “US.”

306-314

Transmitter
ZIP/Postal Code

REQUIRED. Enter the ZIP Code or foreign postal code of the
transmitter. Do not include punctuation or formatting such as
hyphens, periods, and spaces within the entry. An entry must
be five or nine digits if “Transmitter Country” is “US.” A ninedigit entry cannot end with four zeros or four nines if
“Transmitter Country” is “US.” Left justify and space-fill this
entry if less than nine digits.

315-316

Transmitter Country

REQUIRED. Enter the country code of the transmitter. See
General Instruction 5 in Attachment C for information about the
country codes to be entered.

317-332

Transmitter
Telephone Number

REQUIRED. Enter the telephone number of the transmitter.
Enter as a single number string without formatting and
punctuation such as spaces, hyphens, or parenthesis. Left justify
and space-fill the entry.

REQUIRED. Enter “1A.”

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Field
Position(s)

Field Name

Length

333-482

Transmitter Contact
Name

150

REQUIRED. Enter the name of an official contact for the
transmitter. Left justify and space-fill the entry.

483-507

Transmitter Taxpayer
Identification
Number (TIN)

REQUIRED. Enter the U.S. or foreign Taxpayer Identification
Number (TIN) assigned to the transmitter. Do not enter
hyphens, slashes, or invalid entries such as all nines, all zeros, or
“123456789.” Left justify and space-fill the entry.

508-515

Coverage Beginning
Date

REQUIRED. This will be the date of the earliest Effective Date of
Exemption on the file. Enter as a numeric 8-position entry in the
format MMDDCCYY where MM = Month, DD = Day, CC =
Century, and YY = Year.

516-523

Coverage Ending
Date

REQUIRED. This will be the date of the latest Effective Date of
Exemption on the file. Enter as a numeric 8-position entry in the
format MMDDCCYY where MM = Month, DD = Day, CC =
Century, and YY = Year.

524-531

Transmitter Control
Code (TCC)

REQUIRED. Enter the assigned 8-character Transmitter Control
Code (TCC). Do not enter a TCC assigned for testing purposes.

532-534

Batch Sequence
Number (BSN)

Space-fill this field, which is reserved for BSA E-Filing use.

535-1036

Filler

1037-1040

Format Indicator

Space-fill this field, which is reserved for BSA E-Filing use.

1041-1050

User Field

Use this field for any descriptive information you may require;
Space-fill if no entry.

502

Description and Remarks

Space-filled.

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Filer Information (2A) Record – Required
This record identifies information regarding the filing institution that is responsible for
reporting designation of exempt persons. The number of 2A records depends on the number of
different filing institutions included on the file. The 2A record item numbers refer to
Attachment C – Electronic Filing Instructions Part III Filer Information, Items 17-25.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

3-152

Name of bank (Item
17)

150

REQUIRED. Enter the full legal name of the filing institution.
Left justify and space-fill the entry.

153-177

EIN (Item 18)

REQUIRED. Enter the Employer Identification Number (EIN) of
the filing institution. The EIN must be a valid nine-digit entry
with no formatting such as hyphens, slashes, and alpha
characters, or invalid entries such as all nines, all zeros, and
“123456789.” Left justify and space-fill the entry.

178-197

RSSD (Item 19)

Enter the Research Statistics Supervision Discount (RSSD)
number of the filing institution. Left justify and space-fill the
entry. Space-fill if no entry.

198-297

Address (Item 20)

100

REQUIRED. Enter the permanent street address of the filing
institution. Left justify and space-fill the entry.

298-347

City (Item 21)

REQUIRED. Enter the full name of the city of the filing
institution. Left justify and space-fill the entry.

348-350

State (Item 22)

REQUIRED. Enter the appropriate state/territory code of the
filing institution. Left justify and space-fill the entry. Use only
the authorized U.S. Postal Service state, territory, or military
address abbreviations found at
https://www.usps.com/ship/official-abbreviations.htm .

351-359

ZIP Code (Item 23)

REQUIRED. Enter the ZIP Code of the filing institution. ZIP
Codes must be five or nine digits in length and entered without
formatting or special characters such as spaces or hyphens. A
five-digit ZIP Code must be followed by four spaces. A ninedigit ZIP Code cannot end with four zeros or four nines. Left
justify and space-fill the entry.

REQUIRED. Enter “2A.”

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Field
Position(s)

Field Name

Length

Description and Remarks

360

Primary federal
regulator (Item 24)

REQUIRED. Enter the appropriate code to record the filing
institution’s primary federal regulator:
Code Description
B
Federal Reserve Board (FRB)
C
Federal Deposit Insurance Corporation (FDIC)
D
Internal Revenue Service (IRS)
E
National Credit Union Administration (NCUA)
F
Office of the Comptroller of the Currency (OCC)

361

Affiliated Banks
Indicator (Item 25)

If the designation is being made for one or more affiliated banks,
enter “X.” Otherwise, space-fill the entry.

362-1040

Filler

679

Space-filled.

1041-1050

User Field

Use this field for any descriptive information you may require;
Space-fill if no entry.

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Affiliated Bank Information (2B) Record
This record identifies information regarding the bank subsidiary that will be treating the
customer as an exempt person. The number of 2B records depends on the number of different
affiliated banks associated with each filing institution on the file. Filers are permitted to
associate up to 99 2B records for a single exempt person. Multiple 2B records must be grouped
together prior to the associated Exempt Person Information (3A) Record(s). The 2B record item
numbers refer to Attachment C – Electronic Filing Instructions Part III Filer Information Items
17-24.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

3-152

Name of bank (Item
17)

150

REQUIRED. Enter the full legal name of the affiliated bank. Left
justify and space-fill the entry.

153-177

EIN (Item 18)

REQUIRED. Enter the Employer Identification Number (EIN) of
the affiliated bank. The EIN must be a valid nine-digit entry
with no formatting such as hyphens, slashes, and alpha
characters, or invalid entries such as all nines, all zeros, and
“123456789.” Left justify and space-fill the entry.

178-197

RSSD (Item 19)

Enter the Research Statistics Supervision Discount (RSSD)
number of the affiliated bank. Left justify and space-fill the
entry. Space-fill if no entry.

198-297

Address (Item 20)

100

REQUIRED. Enter the permanent street address of the affiliated
bank. Left justify and space-fill the entry.

298-347

City (Item 21)

REQUIRED. Enter the full name of the city of the affiliated bank.
Left justify and space-fill the entry.

348-350

State (Item 22)

REQUIRED. Enter the appropriate state/territory code of the
affiliated bank. Left justify and space-fill the entry. Use only the
authorized U.S. Postal Service state, territory, or military address
abbreviations found at https://www.usps.com/ship/officialabbreviations.htm .

351-359

ZIP Code (Item 23)

REQUIRED. Enter the ZIP Code of the affiliated bank. ZIP
Codes must be five or nine digits in length and entered without
formatting or special characters such as spaces or hyphens. A
five-digit ZIP Code must be followed by four spaces. A ninedigit ZIP Code cannot end with four zeros or four nines. Left
justify and space-fill the entry.

REQUIRED. Enter “2B.”

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Field
Position(s)

Field Name

Length

360

Primary federal
regulator (Item 24)

361-1040

Filler

680

Space-filled.

1041-1050

User Field

Use this field for any descriptive information you may require;
Space-fill if no entry.

Description and Remarks

REQUIRED. Enter the appropriate code to record the affiliated
bank's primary federal regulator:
Code Description
B
Federal Reserve Board (FRB)
C
Federal Deposit Insurance Corporation (FDIC)
D
Internal Revenue Service (IRS)
E
National Credit Union Administration (NCUA)
F
Office of the Comptroller of the Currency (OCC)

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Exempt Person Information (3A) Record – Required
This record identifies information regarding the exempt person and the DOEP filing. The
number of 3A records depends on the number of different exempt persons included on the file.
The 3A record item numbers refer to Attachment C - Electronic Filing Instructions Item 1-2, Part
II Items 3-16, and Part IV Items 26-30.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter “3A.”

3-7

Sequence Number

REQUIRED. Enter a sequential number starting with “00001”
and increment by 1 for each Exempt person Information (3A)
Record.

Filing type (Item 1)

REQUIRED. Enter the appropriate code to record the type of
filing.
Code Description
A
Initial designation
B
Exemption amended
C
Exemption revoked

9-16

Effective Date of
Exemption (Item 2)

REQUIRED. Enter the effective date of exemption as a numeric
8-position entry in the format MMDDCCYY where MM =
Month, DD = Day, CC = Century, and YY = Year. If “Filing type”
is “A Initial designation,” enter the date of the first transaction to
be exempted. If “Filing type” is “B Exemption amended” and
the effective date of the exemption is not being amended, the
date entered should be the same as the exemption date reported
on the initial designation, or if the effective date of the
exemption is being amended, enter the date of the first
transaction to be exempted. If “Filing type” is “C Exemption
revoked,” enter the date of the day following the date of the last
exempted transaction.

17-166

Individual's last
name, or entity's legal
name of the exempt
person (Item 3)

150

REQUIRED. Enter the legal name (if entity) or last name (if
individual) of the exempt person. If the exempt person is a sole
proprietorship, enter the last name of the proprietor in this field.
Enter the remainder of the proprietor’s name in “First Name,”
“Middle Name,” and “Name Suffix.” If the sole proprietorship
has a name separate from the proprietor’s name, enter that name
in “Alternate Name.”

167

Exempt person is
entity

Enter “X” if the exempt person is an entity and space fill the
“First Name, “Middle Name,” and “Name Suffix” fields. Spacefill if no entry.

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Field
Position(s)

Field Name

Length

Description and Remarks

168-202

First Name (Item 4)

REQUIRED (conditional). If the exempt person is an individual,
enter his/her first name. Left justify and space-fill the entry.
Space-fill if “Exempt person is entity” contains “X.”

203-237

Middle Name (Item
5)

Enter the middle name or middle initial of the exempt person.
Left justify and space-fill the entry. Space-fill if no entry or if
“Exempt person is entity” contains “X.”

238-272

Name Suffix (Item 5)

Enter the name suffix such as JR, SR, III, etc. of the exempt
person. Left justify and space-fill the entry. Space-fill if no entry
or if “Exempt person is entity” contains “X.”

273-422

Alternate Name (Item
6)

150

Enter the alternate name of the exempt person (e.g. AKA individual or DBA - entity). Do not include the acronyms
“AKA” or “DBA” with the alternate name. Left justify and
space-fill the entry. Space-fill if no entry.

423-452

Occupation or type of
business (Item 7)

Enter the exempt person’s occupation or type of business. Left
justify and space-fill the entry. Space-fill if no entry.

453-458

NAICS Code (Item
7a)

Enter the NAICS Code associated with the exempt person’s
occupation or type of business. Access the NAICS Code list from
the BSA E-Filing Web Site
http://bsaefiling.fincen.treas.gov/main.html . Left justify and
space-fill this entry. Space-fill if no entry.

459-558

Address (Item 8)

100

REQUIRED. Enter the permanent address of the exempt
person’s business location. For exempt persons doing business at
more than one physical location, enter the local headquarters
address or local address of the exempt person. For a sole
proprietorship, enter the business address of the sole
proprietorship rather than the home address of the sole
proprietor, unless they are the same. Left justify and space-fill
the entry.

559-608

City (Item 9)

REQUIRED. Enter the full name of the city of the exempt
person’s business location. Left justify and space-fill the entry.

609-611

State (Item 10)

REQUIRED. Enter the state code of the exempt person’s business
location. Left justify and space-fill the entry. Use only the
authorized U.S. Postal Service state, territory, or military address
abbreviations found at https://www.usps.com/ship/officialabbreviations.htm .

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Field
Position(s)

Field Name

Length

612-620

ZIP Code (Item 11)

REQUIRED. Enter the ZIP Code of the exempt person’s business
location. ZIP Codes must be five or nine digits in length and
entered without formatting or special characters such as spaces
or hyphens. A five-digit code must be followed by four spaces.
A nine-digit code cannot end with four zeros or four nines. Left
justify and space-fill this entry.

621-645

TIN (Item 12)

REQUIRED. Enter the exempt person’s Taxpayer Identification
Number (TIN). The TIN must be a valid nine-digit entry with no
formatting such as hyphens, slashes, alpha characters, or invalid
entries such as all nines, all zeros, or “123456789.” Left justify
and space-fill the entry.

646

TIN type (Item 13)

REQUIRED. Enter the appropriate code to record the exempt
person’s TIN type.
Code Description
A
EIN
B
SSN/ITIN

647-746

E-mail address (Item
14)

100

Enter the exempt person’s email address. Left justify and spacefill the entry. Space-fill if no entry.

747-762

Phone Number (Item
15)

Enter the telephone number of the exempt person. The
telephone number must be a total of 10 digits in length,
beginning with the exempt person’s 3 digit area code followed
by a 7 digit telephone number. Enter as a single number string
without formatting and punctuation such as spaces, hyphens, or
parenthesis. Left justify and space-fill the entry. Space-fill if no
entry.

763-768

Extension (if any)
(Item 15a)

Enter the exempt person’s telephone extension. Enter as a single
number string without formatting and punctuation such as
spaces, hyphens, or parenthesis. Left justify and space-fill the
entry. Space-fill if no entry.

769

Type of exempt
person (Item 16)

REQUIRED. Enter the appropriate code to record the type of
exempt person.
Code Description
A
Listed company
B
Listed company subsidiary
C
Eligible non-listed business
D
Payroll customer

770-919

Print Name (Item 26)

150

Description and Remarks

Enter the name of the bank official who authorized this
exemption. Left justify and space-fill the entry.

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Field
Position(s)

Field Name

Length

Description and Remarks

920-954

Title (Item 27)

Enter the title of the bank official who authorized this
exemption. Left justify and space-fill the entry.

955-970

Phone Number (Item
29)

Enter the telephone number of the bank official identified as the
authorizer of this report. The telephone number must be a total
of 10 digits in length, beginning with the exempt person’s 3 digit
area code followed by a 7 digit telephone number. Enter as a
single number string without formatting and punctuation such
as spaces, hyphens, or parenthesis. Left justify and space-fill the
entry.

971-976

Phone Number Ext.
(Item 29a)

Enter the telephone extension of the bank official identified as
the authorizer of this report. Enter as a single number string
without formatting and punctuation such as spaces, hyphens, or
parenthesis. Left justify and space-fill the entry. Space-fill if no
entry.

977-984

Date of signature
(Item 30)

Enter the date of signature (i.e. authorization to submit) as a
numeric 8-position field in the format MMDDCCYY where MM
= month, DD = day, CC = Century, and YY = year. Space-fill if no
entry.

985-998

BSA Identifier (BSA
ID)/ Document
Control Number
(DCN)

REQUIRED (conditional). If “Filing Type” is “B Exemption
amended” or “C Exemption revoked,” enter the BSA ID/DCN
previously assigned by FinCEN to the DEP. If the BSA ID/DCN
is unknown, zero-fill this field. If ”Filing Type” is “A Initial
designation,” space-fill this field.

999-1040

Filler

Space-filled.

1041-1050

User Field

Use this field for any descriptive information you may require;
Space-fill if no entry.

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Filer Information Summary (9B) Record – Required
There must be one of these record types for each Filer Information (2A) Record reported on the
file. This record contains counts of the number of 2B and 3A record types associated with the
Filer Information (2A) Record.

Field
Position(s)

Field Name

Length

1-2

Record Type

REQUIRED. Enter “9B.”

3-9

Affiliated Bank
Information (2B)
Record Count

REQUIRED. Enter the number of Affiliated Bank Information
(2B) Records for the associated Filer Information (2A) Record.

10-16

Exempt Person
Information (3A)
Record Count

REQUIRED. Enter the number of Exempt Person Information
(3A) Records for the associated Filer Information (2A) Record.

17-1040

Filler

1041-1050

User Field

1024
10

Description and Remarks

Space-filled.
Use this field for any descriptive information you may require;
Space-fill if no entry.

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File Summary (9Z) Record – Required
There should only be one of these record types on the file and it must be the very last record
reported. This record contains counts of the number of 2A, 2B, and 3A record types associated
with the Transmitter (1A) Record.

Field
Position(s)

Field Name

Length

1-2

Record Type

REQUIRED. Enter “9Z”.

3-9

Filer Information (2A)
Record Count

REQUIRED. Enter the total number of Filer Information (2A)
Records.

10-16

Affiliated Bank
Information (2B)
Record Count

REQUIRED. Enter the total number of Affiliated Bank
Information (2B) Records.

17-23

Exempt person
Information (3A)
Record Count

REQUIRED. Enter the total number of Exempt person
Information (3A) Records.

24-1040

Filler

1041-1050

User Field

1017
10

Description and Remarks

Space-filled.
Use this field for any descriptive information you may require;
Space-fill if no entry.

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Acknowledgement Record Formats
The DOEP batch acknowledgement file defined below is provided in ASCII format. The
acknowledgement file will contain a corresponding acknowledgement record for each record
received on the batch file.

Acknowledgement Transmitter (1A) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
transmitter data received by FinCEN.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field position 1-2 of the incoming 1A record.

3-10

Coverage Beginning
Date

Field position 508-515 of the incoming 1A record. Entered as a
numeric 8-position entry in the format MMDDCCYY where
MM = Month, DD = Day, CC = Century, and YY = Year.

11-18

Coverage Ending Date

Field position 516-523 of the incoming 1A record. Entered as a
numeric 8-position entry in the format MMDDCCYY where
MM = Month, DD = Day, CC = Century, and YY = Year.

19-26

Transmitter Control
Code (TCC)

Field position 524-531 of the incoming 1A record.

27-29

Batch Sequence
Number (BSN)

References the batch number of the original transmission file
(532-534, 1A record). This number is for BSA E-Filing internal
use only.

30-59

Error Codes

Please see Attachment A - Error Code List for a detailed
description of each error code. Error codes associated with this
record begin with a “T” and are left-justified. Unused error code
positions are zero filled.

60-69

User Field

Field Positions 1041-1050 of the incoming 1A record.

70-90

Filler

Space-filled.

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Acknowledgement Filer Information (2A) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the Filer
Information (2A) Record data received by FinCEN.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field position 1-2 of the incoming 2A record.

3-27

Filer EIN

Field position 153-177 of the incoming 2A record.

28-57

Error Codes

Please see Attachment A - Error Code List for a detailed
description of each error code. Error codes associated with this
record are three alphanumeric characters in length and are leftjustified. Unused error code positions are zero filled.

58-67

User Field

Field – Positions 1041-1050 of the incoming 2A record.

68-90

Filler

Space filled.

Acknowledgement Affiliated Bank Information (2B) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Affiliated Bank Information (2B) Record data received by FinCEN.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field position 1-2 of the incoming 2B record.

3-27

Affiliated Bank EIN

Field position 153-177 of the incoming 2B record.

28-57

Error Codes

58-67

User Field

Field – Positions 1041-1050 of the incoming 2B record.

68-90

Filler

Space filled.

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Acknowledgement Exempt Person Information (3A) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Exempt Person Information (3A) Record data received by FinCEN.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field position 1-2 of the incoming 3A record.

3-7

Sequence Number

Field position 3-7 of the incoming 3A record.

8-21

BSA Identifier

A unique identifying number assigned by FinCEN for each
DOEP in the file.

22-51

Error Codes

52-61

User Field

Field Positions 1041-1050 of the incoming 3A record.

62-90

Filler

Space filled.

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Acknowledgement Trailer for Transmitter (9Z) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record is a systems control record and it summarizes the data processed by
FinCEN.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field position 1-2 of the incoming 9Z record.

3-12

Number of Filer
Information (2A)
Records

Generated by FinCEN.

13-22

Number of
Designation of
Exempt Person
Information (3A)
Records

Generated by FinCEN.

23-52

Error Codes

53-62

User Field

Field Positions 1041-1050 of incoming 9Z record.

63-90

Filler

Space filled.

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Attachment A – Error Code List
Error
Code

Error Description

Record

Field
Position

Report
Field
Number

Fatal Errors
*A fatal error will result in the rejection of the batch file (not including error code F24).
F02

Number of records reported does not match the computer
count for the 2A record.

F03

Number of records reported does not match the computer
count for the 2B record.

F04

Number of records reported does not match the computer
count for the 3A record in the file.

F11

A required 2A record is missing from the submitted file.

F13

A required 3A record is missing from the submitted file.

F16

A required 1A record is missing from the submitted file.

F18

A required 9Z record is missing from the submitted file.

F24

Number of forms reported on the batch form does not
match the computed count of the forms found in the file.
Note: This error is not returned in the acknowledgement
file. The Batch Form is used when submitting a batch file
via the website. If this error is returned via the web site, do
not resubmit the file with a corrected value for number of
forms. This error is to assist with ensuring the filer has
uploaded the correct file for processing.

F21

A required 9B record is missing from the submitted file.

F34

An invalid record type was present in Field Position 1-2 in
one or more records of the submitted file.

F37

A duplicate “Transaction Sequence”/”Transaction
Sequence Number” was present in the submitted file.

F38

The “Transaction Sequence”/”Transaction Sequence
Number” is missing from the submitted file.

F39

A non-numeric “Transaction Sequence”/”Transaction
Sequence Number” is present in the submitted file.

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Error
Code

Error Description

Record

F88

The Transmitter Control Code (TCC) specified in the file is
not a valid production TCC.

F89

The submitted batch contains an invalid format indicator
in the 1A record.

F93

An invalid line terminator was present on the submitted
file

F94

Cannot continue processing the submitted file because of
previous errors encountered.

F96

One, or more, invalid characters were present in the
submitted file.

F97

An invalid record sequencing was present on the
submitted file.

F98

An invalid record length was present on the submitted file.

F99

Unknown file error. Please contact the BSA E-Filing Help
Desk for assistance.

Field
Position

Report
Field
Number

Validation Errors
*Validation errors are for informational purposes only.
E01

This submission cannot be accepted because it contains
significant errors. Please fix and resubmit the file.

E02

This submission has been accepted and will be processed
by FinCEN, however it contains some errors which need to
be corrected once this submission has been acknowledged.
File Errors
*File error codes containing an asterisk (*) are primary errors that must be corrected.

T01

Transmitter name is blank.

3-152

T02

Transmitter street address is blank.

153-252

T03

Transmitter city is blank

253-302

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Error
Code

Error Description

Record

Field
Position

Report
Field
Number

T04

Transmitter state is blank.

303-305

T05

Transmitter ZIP Code is blank.

306-314

T13

Transmitter country is blank.

315-316

T06

Transmitter telephone number is blank.

317-332

T07

Transmitter contact name is blank.

333-482

T08

Transmitter TIN is blank.

483-507

T09

Coverage beginning date is blank or invalid.

508-515

T10

Coverage ending date is blank or invalid.

516-523

T12

The Transmitter Control Code is blank.

524-531

D01*

Bank name is blank.

2A/2B

3-152

D02*

EIN is blank.

2A/2B

153-177

D03*

EIN is an invalid number string such as all zeros, all nines,
123456789, or not equal to nine numbers.

2A/2B

153-177

D04

Address is blank.

2A/2B

198-297

D05

City is blank.

2A/2B

298-347

D06

State is blank.

2A/2B

348-350

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Error
Code

Error Description

Record

Field
Position

Report
Field
Number

D07

State is not a valid state code.

2A/2B

348-350

D08

ZIP Code is blank.

2A/2B

351-359

D09

ZIP Code is a nine digit code ending in four zeros/nines.

2A/2B

351-359

D10

ZIP Code is not equal to five or nine digits or contains nonnumeric values.

2A/2B

351-359

D11

Primary federal regulator is blank.

2A/2B

360-360

D12

Primary federal regulator contains an invalid code.

2A/2B

360-360

D13

Affiliated banks indicator contains an invalid code.

361-361

D14

Filing type is blank.

D15

Filing type contains an invalid code.

D16*

Effective date of exemption is blank.

9-16

D17*

Effective date of exemption is not a numeric 8-position
entry in MMDDCCYY format where MM = month, DD =
day, CC = Century, and YY = year.

9-16

D18*

Effective date of exemption is not less than or equal to the
date of signature.

9-16

D19*

Effective date of exemption is not greater than or equal to
January 1, 1900.

9-16

D20*

Exempt person last/legal name is blank.

17-166

D21

Exempt person is entity contains an invalid code.

167-167

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Error
Code

Error Description

Record

Field
Position

Report
Field
Number

D22*

Exempt person first name is blank and the entity box is not
checked.

168-202

D23*

TIN is blank.

621-645

D24*

TIN is an invalid number string such as all zeros, all nines,
123456789, or not equal to nine numbers.

621-645

D25

TIN type is blank.

646-646

D26

TIN type contains an invalid code.

646-646

D27

E-mail address is in an invalid format.

647-746

D28

Exempt person phone number contains non-numeric
values, is in an invalid format, or is not equal to ten
numbers.

747-762

D29

Type of exempt person contains an invalid code.

769-769

D30

Type of exempt person is blank.

769-769

D31

Authorizer phone number contains non-numeric values, is
in an invalid format, or is not equal to ten numbers.

955-970

D32

Date of signature is not a numeric 8-position entry in
MMDDCCYY format where MM = month, DD = day, CC =
Century, and YY = year.

977-984

D33

Date of signature is greater than the current date.

977-984

D34

Prior report BSA Identifier/ Document Control Number
(DCN) is blank.

985-998

D35

Prior report BSA Identifier/ Document Control Number
contains non-numeric values.

985-998

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Attachment B – Error Correction Instructions
This attachment identifies the requirements and procedures for correcting DOEP errors
reported to batch filers during the DOEP acknowledgement process.
Error Categories:
There are two types of errors identified in batch files: batch file format errors that may result in
automatic rejection of a batch file and data errors that represent errors in data entered in
individual fields. Some format errors are termed fatal errors because they prevent the batch file
from being processed. For example, error F18 “A required 9Z record is missing from the
submitted file” is a fatal format error because each batch file must contain a 9Z record. All
format error codes begin with the letter “F.” All data error codes begin with the letter “T” or
“D.” Error D01 “Bank name is blank” is a data error because it indicates data is missing from a
record. Generally, data error codes indicate that data entries are missing or incorrect.
File errors are classified as primary or secondary errors, depending on their importance.
Primary errors are file errors that violate electronic filing requirements or report instructions
and so degrade DOEP data quality that they must be corrected. Primary errors make it difficult
for regulators, analysts, and law enforcement investigators to locate the DOEPs filed by specific
banks or on specific persons in the database. Examples of such errors include blank legal name
or missing filer Employer Identification Number. Attachment A – Error Code List identifies
primary errors by adding an asterisk (*) to the three-digit file error codes.
Secondary errors are file errors that violate electronic filing requirements or report instructions
but have a lesser impact on DOEP data quality. Examples of secondary errors are ZIP Codes
that end in four zeros (e.g. 123450000) or invalid telephone numbers.
Correction Requirements:
Filers should immediately correct and resubmit a batch file rejected for fatal errors when
notified by FinCEN the batch file was not accepted. Rejection of a batch file does not relieve the
filer of the responsibility to file a DOEP within the time frames established by the BSA.
When a batch file is accepted by the BSA E-Filing Program, filers receive an acknowledgement
file that records all errors identified in the batch file. A DOEP that contains primary errors must
be re-filed as a corrected DOEP with the primary errors and any secondary errors corrected.
DOEPs that contain only secondary errors need not be corrected. FinCEN requires that filers
prevent all reported errors in their future filings.
FinCEN recommends that primary error corrections be made no later than 30 days after
receiving error notifications. Furthermore, FinCEN recommends that filers remedy any systemic
problems in their electronic submissions within 30 days of receiving error notifications. If
technical issues prevent filers from implementing corrections within these time frames, filers
should notify FinCEN by writing to:

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Office of Compliance
P.O. Box 39
Vienna, VA 22183
This correspondence should explain the technical issues that prevent meeting this time frame,
provide an estimate of when the issues will be resolved, and include a contact name and
telephone number.
Correction Procedures:
A DOEP batch file is rejected when it contains fatal format errors. The filer must correct all
errors identified in the batch file and resubmit the batch file to BSA E-Filing. Because they were
not accepted by FinCEN, all DOEPs in the re-submitted batch file must retain their original
filing type. Do not identify DOEPs in a refiled batch file as corrected reports unless they
originally were filed as corrected reports in the rejected batch file.
If errors in an accepted batch file involve primary file errors, filers must file corrected reports on
all DOEPs containing primary file errors using the following procedures:


Make the corrections to both the primary and secondary errors in all DOEPs that contain
primary errors. Filers are encouraged, but not required, to correct any secondary errors
in DOEPs that contained no primary errors.
NOTE: Do not correct any error codes that begin with “T.” Instead, ensure any “T”
errors are prevented in future batch files.



Enter “B” at Field Position 8 “Filing type” in the Exempt Person Information (3A)
Record for each corrected DOEP.



Enter the prior DOEP’s BSA Identifier (from the DOEP acknowledgement file) at Field
Positions 985 – 998 “BSA Identifier (BSA ID)/Document Control Number (DCN)” in the
Exempt Person Information (3A) Record for each corrected DOEP.



Ensure that Field Positions 977 - 984 contain a new “Date of signature” in the Exempt
Person Information (3A) Record for each corrected DOEP.



Complete all other data in the DOEPs in their entirety.



Retransmit the corrected DOEPs in a new batch file. Do not re-transmit the original
batch file because this will cause duplicate database entries on any DOEPs that were not
corrected.

FinCEN monitors DOEP filings to identify financial institutions that fail to correct primary
errors in prior filings or to prevent previously-reported errors of any type in future filings.
FinCEN may report such failures to a financial institution’s primary federal/state regulator or
BSA examiner.

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Attachment C – Electronic Filing Instructions
The following instructions apply only to the electronic filing of the Designation of Exempt
Person (DOEP) report, FinCEN Form 110, through FinCEN’s BSA E-Filing System. These
instructions do not apply to any other current or prior Bank Secrecy Act reports.
General Information
The Bank Secrecy Act and its implementing regulations require banks to file currency
transaction reports on transactions in currency of more than $10,000. The regulations also
permit a bank to exempt certain customers from currency transaction reporting in accordance
with 31 CFR 1020.315.
Banks are the only type of financial institutions that may exempt customers from CTR
filing requirements. The term bank is defined in 31CFR 1010.100(d); and includes savings and
loan associations, thrift institutions, and credit unions.
The customers that the bank may exempt are called “exempt persons.” An exempt
person may be a bank, government agency/government authority, listed company, listed
company subsidiary, eligible non-listed business, or payroll customer.
A bank may, but is not required to, use this report to notify the Treasury that the bank
has revoked the designation of a customer as an exempt person.
FinCEN encourages banks to use the exemption procedure to the fullest extent. FinCEN
reminds banks of their continuing obligation to monitor for and report suspicious activity with
respect to transactions of all customers, including currency transactions conducted by exempt
persons.
General Instructions
1. Filing: The DOEP should be e-filed through the BSA E-Filing System. Go to
http://bsaefiling.fincen.treas.gov/index.jsp to register. Any bank that wishes to designate a
customer as an exempt person must file the DOEP no later than 30 days after the first
transaction to be exempted.
2. Report Completion. Complete the report in accordance with instructions for each
item. Unless there is a specific instruction to the contrary, leave blank any items that do not
apply.

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3. Dates. Enter all dates in MM/DD/ YYYY format where MM = month, DD = day, and
YYYY = year. Precede any single number with a zero, i.e., 01, 02, etc.
4. Numbers. Enter all numbers such at identifying and telephone numbers as single
number strings without formatting or punctuation such as spaces, hyphens, or parenthesis.
5. Addresses. Enter the permanent street address, city, two-letter state or territory
abbreviation, and ZIP Code. Provide the apartment number or suite number, if known,
following the street address. A non-location address such as a post office box or rural route
number should be used only if no other street address information is available. ZIP Codes must
be five or nine digits. ZIP Codes must be entered without formatting or special characters such
as hyphens. For example, the ZIP Code 12354-6120 would be entered as 123546120. Complete
any address item that is known, even if the entire address is unknown. No abbreviations are
permitted in city names, which must be completely spelled out. A U.S. city name should match
the city name used by the U.S. Postal Service for the associated state and ZIP Code. Use only the
authorized U.S. Postal Service state, territory, or military address abbreviations found at
https://www.usps.com/ship/official-abbreviations.htm. Foreign batch filers who are completing
the Transmitter (1A) Record with foreign address information must use only the Canadian and
Mexican state/territory/province codes and ISO country codes approved for use by FinCEN. For
Canadian provinces and territories use the Canada Post Corporation codes found at
http://www.canadapost.ca/tools/pg/manual/PGaddress-e.asp#1380608. For Mexican states and
territories use the ISO 3166-2 three-letter codes found at
http://www.commondatahub.com/live/geography/state_province_region/iso_3166_2_state_code
s. For all countries use the ISO 3166-1 two-letter country codes found at
http://www.iso.org/iso/country_names_and_code_elements.
6. Prohibited Words. Do not use the following words or their variations in fields:
a)
b)
c)
d)
e)
f)
g)
h)
i)
j)
k)
l)

AKA
CUSTOMER
DBA
NONE
NOT APPLICABLE
OTHER
SAME
SAME AS ABOVE
SEE ABOVE
UNKNOWN
VARIOUS
XX

7. Name Editing Instructions. Because many names do not consist of a single first
name, middle name, and last name, care must be taken to ensure these names are entered

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properly in the BSA SAR. This is especially important when there are separate fields for the last
name, first name, and middle name. Some names have multiple surnames (family names) or
multiple given names that do not include a middle name. Others may not be written in [first
name] [middle name] [last name] order. Multiple surnames must be entered in the last name
field. For example, Hispanic names may be written in the order of given name, father's last
name, and mother's last name, e.g., “Juan Vega Santiago.” Thus the surname “VEGA
SANTIAGO” would be entered in the last name field with “JUAN” entered in the first name
field. Some Hispanic surnames consist of three names (e.g., father’s last name, mother’s last
name, and husband’s father’s last name in the case of a married woman). In that case all three
would be entered in a last name field. Hispanic names do not have middle names, so a multiple
Hispanic given name such as “Rosa Maria” would be recorded in the first name field. In some
cultures names consist of multiple first names and a single family name, not necessarily in (first
name) (last name) order. For example, the Korean name “Kim, Chun Nam” consists of the
family name “Kim” and the first name “Chun Nam” separated by a comma and space. There is
no middle name. In this case “KIM” would be entered in the last name field and “CHUN
NAM” would be entered in the first name field. Nothing is entered in the middle name field.
When an individual name is entered in a single name field it should be entered in [first name]
[middle name] [last name] order regardless of any foreign naming conventions. Thus, “Kim,
Chun Nam” would be entered as “CHUN NAM KIM” in a single name field. Punctuation and
special characters should be used in names only when they are part of the name. For example,
the period in “Expedia.Com” should be included because it is part of the name. Placing a
period after a middle initial would be prohibited because the period is not part of the middle
name. Abbreviations in names are prohibited unless an abbreviation is part of a legal
name. Entry of middle initials is permitted when a middle name is unknown. A name suffix
may be abbreviated, i.e. Junior can be JR, Senior can be SR, the Third can be III, etc.
Specific Instructions
Part I Filing Information
Item 1--Type of filing. Check only one of the three boxes 1a “Initial designation,” 1b
“Exemption amended,” or 1c “Exemption revoked.” If the DOEP amends or revokes a prior
designation, include the Document Control Number or BSA Identifier of the prior filing in the
associated number field. If this number is unknown, enter “00000000000000” in the number
field. Leave the number field blank if the filing is an initial designation.
Item 2--Effective date of the exemption. For an initial designation, enter the date of the first
transaction to be exempted. For amended DOEPs, if the effective date of the exemption is not
being amended, the date entered should be the same date the bank used in the “effective date of
the exemption box” when the initial designation was made. If the effective date of the
exemption is being amended, enter the revised date of the first transaction to be exempted. If an

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exemption is being revoked, enter the day after the date of the last transaction that was
exempted.
Part II Exempt Person Information
Check here if entity. Check this box if the exempt person is an entity. Leave this box blank
if the exempt person is an individual.
Item 3—Individual’s last name or entity’s legal name of the exempt person. If the exempt
person is an entity, enter the full legal name of the exempt person as it is shown on the charter
or other document creating the entity. For exempt individuals such as sole proprietorships,
enter individual’s last name.
Item 4—First name. Enter the first name of the exempt person if an individual.
Item 5—Middle name. Enter the middle name or initial of the exempt person if an individual.
Item 5—Suffix. Enter the name suffix such as JR, SR, III, etc. of the exempt person if an
individual.
Item 6—Alternate name. Enter the individual’s also known as (AKA) or the entity’s doing
business as (DBA) name if different from the name entered in Items 3-5. Do not include the
acronyms AKA or DBA with the name.
Item 7—Occupation or type of business. Record the occupation, profession, or type of business
of the exempt person. Use specific descriptions such as doctor, carpenter, attorney, used car
dealership, plumber, truck driver, hardware store, etc. Do not use non-descriptive occupations
such as businessman, merchant, retailer, or self-employed without indicating the nature of the
occupations, e.g. shoe merchant or self-employed accountant.
Item 7a—NAICS Code. Select the North American Industry Classification System (NAICS)
code for the occupation entered in Item 7. Batch filers should only use codes from the NAICS
Code list on the BSA E-Filing Web Site at http://bsaefiling.fincen.treas.gov/main.html.
Item 8—Address. Enter the permanent street address of the business location of the exempt
person. For exempt persons doing business at more than one physical location, enter the local
headquarters address or local address of the exempt person. For individuals such as sole
proprietorships, enter the business address of the individual rather than the home address,
unless they are the same.
Item 9—City. Enter the city associated with the business location of the exempt person. Do not
abbreviate the city name (see General Instruction 5).

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Item 10—State. Select the state or territory associated with the business location of the exempt
person.
Item 11—ZIP Code. Enter the ZIP Code associated with the business location of the exempt
person. Use only the five or nine-digit ZIP Code assigned to the address by the U.S. Postal
Service.
Item 12—TIN. Enter the Employer Identification Number (EIN) or Social Security Number
(SSN) of the exempt person. If a sole proprietorship does not have an EIN, enter the proprietor’s
Social Security Number (SSN).
Item 13—TIN type. Select the TIN type associated with the TIN in Item 12.
Item 14—E-mail address. Enter the e-mail address associated with the exempt person.
Item 15—Phone number. Enter the telephone number of the exempt person. Enter as a single
number string without formatting and punctuation such as spaces, hyphens, or parenthesis.
Item 15a—Extension. Enter the telephone number extension of the exempt person.
Item 16—Type of exempt person. Check only one of the four boxes 16a “Listed company,” 16b
“Listed company subsidiary, 16c “Eligible non-listed business, or 16d “Payroll customer.”
Part III Filer Information
Item 17—Name of bank. Enter the bank’s full legal name.
Item 18—EIN. Enter the bank’s Employer Identification Number (EIN).
Item 19—RSSD. Enter the bank’s Research Statistics Supervision Discount (RSSD) number.
Items 20 - 23—Address. Enter the bank’s headquarters address.
Item 24—Primary federal regulator. Select the bank’s primary federal regulator from the list.
The options are:
Federal Reserve Board (FRB)
Federal Deposit Insurance Corporation (FDIC)
Internal Revenue Service (IRS)
National Credit Union Administration (NCUA)
Office of the Comptroller of the Currency (OCC)

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Item 25—Affiliated banks. A parent bank holding company or one of its bank subsidiaries may
make the designation of exempt person on behalf of some or all bank subsidiaries of the holding
company so long as the designation lists each bank subsidiary that will treat the customer as an
exempt person. Check the box in Item 25 and complete an Affiliated Bank Information section
on each affiliated bank. Batch filers will complete an Affiliated Bank Information (2B) Record on
each affiliated bank.
Part IV Signature
Item 26—Print name. Enter the name of the bank official who authorized the exemption.
Item 27—Title. Enter the title of the bank official who authorized the exemption.
Item 28—Signature. This report is signed when the discrete report or batch file is signed with a
personal identification number (PIN) assigned to an appropriate bank official by the BSA EFiling System.
Item 29—Phone number. Enter the telephone number of the bank official who authorized the
exemption.
Item 29a—Extension. Enter the telephone number extension of the bank official who authorized
the exemption.
Item 30—Date of signature. If the DOEP is a discrete filing, this date will be supplied by the
BSA E-Filing System when the report is signed with a PIN. Batch filers should enter the
signature date in the 3A record.
Paperwork Reduction Act Notice: The purpose of this report is to provide an effective means
for banks and depository institutions to exempt eligible customers from currency transaction
reporting. This report is required by law, pursuant to 31 CFR 1020.315 Federal law enforcement
and regulatory agencies, including the U.S. Department of Treasury and other authorized
authorities, may use and share this information. You are not required to provide the requested
information unless a report displays a valid OMB control number. Public reporting and
recordkeeping burden for this report is estimated to average 70 minutes per response, and
includes time to gather and maintain information for the required report, review the
instructions, and complete the information collection. The record retention period is five years.
Send comments regarding this burden estimate, including suggestions for reducing the burden,
to Financial Crimes Enforcement Network, Attention: Paperwork Reduction Act, P. O. Box 39,
Vienna, VA 22183-0039.

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Secure Data Transfer Mode Users
For filers using this option for filing, SDTM users can submit a single file containing the FinCEN
DOEP batch data. The file naming convention is as follows:
Submission type - DOEPST
Date/Time - This will be a date-time stamp to guarantee filename uniqueness
year – YYYY
month – MM day – DD
hour – hh
minute – mm
second – ss
Organization name –custom naming by the submitting organization.
Example file name:
DOEPST.20120609153015.BANKORGNAME

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File Type	application/pdf
File Title	FinCEN Designation of Exempt Person (FinCEN Form 110) Electronic Filing Requirements
Subject	Release Date March 2015 – Version 1.2
Author	Northrop Grumman Corporation
File Modified	2015-03-12
File Created	2015-03-12