Author: Jeremy Clifton, CRCM, CAMS
FinCEN recently released a Notice to Financial Institution Customers on Beneficial Ownership Information Requirements. This document compares and contrasts differences in documentation businesses need for FinCEN Beneficial Ownership Information and what financial institutions need for CDD related beneficial ownership requirements. See the link below for the press release and notice. We think this notice will be helpful in explaining such differences and educating customers.
Many clients have asked but we do not have any substantial news on the upcoming CDD rule for beneficial ownership at this time. The updated CDD rule is the last of the three beneficial ownership related rules and will greatly affect financial institutions’ beneficial ownership processes. We covered this area in more detail in our prior blog about the finalization of the Access Rule. However, FinCEN has updated the CDD rule’s expected notice of proposed rulemaking date to be in October 2024 with a proposed comment period to end in December 2024. FinCEN has kicked the can on these dates several times but is up against a mandate to have the final rule by January 2025. One other area of interest is noted from FinCEN’s BOI FAQs (O. 1.) which is that access to the beneficial ownership information is expected for financial institutions in spring of 2025.
FinCEN’s Notice to Financial Institution Customers on Beneficial Ownership Information Requirements
FinCEN recently released a Notice to Financial Institution Customers on Beneficial Ownership Information Requirements. This document compares and contrasts differences in documentation businesses need for FinCEN Beneficial Ownership Information and what financial institutions need for CDD related beneficial ownership requirements. See the link below for the press release and notice. We think this notice will be helpful in explaining such differences and educating customers.
Many clients have asked but we do not have any substantial news on the upcoming CDD rule for beneficial ownership at this time. The updated CDD rule is the last of the three beneficial ownership related rules and will greatly affect financial institutions’ beneficial ownership processes. We covered this area in more detail in our prior blog about the finalization of the Access Rule. However, FinCEN has updated the CDD rule’s expected notice of proposed rulemaking date to be in October 2024 with a proposed comment period to end in December 2024. FinCEN has kicked the can on these dates several times but is up against a mandate to have the final rule by January 2025. One other area of interest is noted from FinCEN’s BOI FAQs (O. 1.) which is that access to the beneficial ownership information is expected for financial institutions in spring of 2025.
FinCEN’s Notice to Financial Institution Customers on Beneficial Ownership Information Requirements
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