Beneficial Ownership Receives Relief from FinCEN
By Gina Ellis, CRCM
FinCEN issued a ruling May 16, 2018 to provide a 90-day exceptive relief from certain obligations of the Beneficial Ownership Rule. FinCEN is offering this exceptive relief for specific products such as certificates of deposit or loans that automatically rollover or renew and that were established prior to the effective date of the beneficial ownership requirements, May 11, 2018.
Therefore, if you have certificates of deposit or loan accounts that automatically renew and were established prior to May 11, 2018 for legal entity customers, you will not need to obtain the beneficial ownership information for renewals during the period May 11, 2018 through August 9, 2018. We are happy FinCEN has recognized that most banks do not consider these renewing products to be new accounts and instead continuing relationships. Hopefully this exceptive relief will become permanent after the 90-day review period!
You can review the FinCEN ruling here: https://www.fincen.gov/sites/default/files/2018-05/FinCEN%20Ruling%20CD%20and%20Loan%20Rollover%20Relief_FINAL%20508-revised.pdf
As always, we are here to help solve your compliance dilemmas. Contact us at www.americanbanksystems.com or call (405) 607-7000.