certificate of deposit

FinCEN Issues Extension of Exceptive Relief for Certificate of Deposit and Loan Renewals

The top BSA hotline question TCA has received in August inquired about an update to FinCEN’s May 16, 2018 Exceptive Relief (FIN‐2018‐R002) delaying the requirement to obtain a Certification of Beneficial Ownership for certificate of deposit and loan renewals. Since FinCEN considered these to be new accounts, financial institutions expressed concerns over the many challenges of obtaining a certification for legal entity customers. The update is here!

FinCEN issued an extension to the May 16, 2018 exceptive relief on August 8, 2018 in FIN‐2018‐R003. FinCEN is extending the exception relief that was scheduled to expire on August 9, 2018 by 30 days to September 8, 2018. FinCEN stated in the exceptive relief that it is still evaluating the concerns with this requirement.

What does this mean to your institution?

If your institution decided to take advantage of the May 2018 exceptive relief, you do not need to take any action at this time. If FinCEN does not make this relief permanent, TCA encourages you to have an implementation plan.

For institutions that are already contacting customers to obtain Certifications, you may continue this process, but you do not need to take any action against those who do not respond immediately since the compliance date has been extended.

As your BSA Partner, the BSA Action Team (BAT) will continue to monitor FinCEN’s and the prudential regulators’ approach to the beneficial ownership rule. In the meantime, TCA’s BAT has resources for your beneficial ownership questions:

Contact a member of TCA’s BAT at [email protected] with your beneficial ownership questions, to schedule a process review of your implementation or your next BSA Audit.

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