he exceptive relief for CD renewals, loan renewals and modifications, and safe deposit box renewals has been made permanent. The industry has challenged FinCEN for some time with the operational challenges of obtaining beneficial ownership certifications for these auto‐renewing products. FinCEN finalized this exceptive relief by making it permanent on September 7, 2018 in FIN‐2018‐R003. Originally, FinCEN issued an extension to the May 16, 2018 exceptive relief on August 8, 2018.
What does this mean to your institution?
If your institution has any one of the following products, you are not required to collect beneficial ownership information if the following occurs:
- A certificate of deposit (CD) rollover.
- A loan renewal, modification or extension (e.g., setting a later payoff date) that does not require underwriting review and approval.
- A renewal, modification or extension of a commercial line of credit or consumer credit card account (e.g., a later payoff date is set) that does not require underwriting review and approval.
- A safe deposit box rental renewal.
Keep in mind, if one of these customers opens a new account, beneficial ownership certification is required.
Have you tested your compliance with beneficial ownership? Let TCA spot‐check for you! [email protected]