FinCEN finally issued the long-awaited FAQs concerning the upcoming Beneficial Ownership and customer due diligence rule. The FAQs address multiple implementation questions posed by the industry following the release of the final rule and first set of FAQs. Important highlights include clarification on requirements when a business is identified as a beneficial owner (FAQ 3), using previously gathered CIP information for verifying beneficial owners (FAQ 7), and what is required when a CD rolls over or a loan is renewed (FAQ 12). It is highly recommended that institutions review the FAQs as soon as possible as implementation and training changes will be required prior to the May 11, 2018 required compliance date. The FAQs can be found here.