RLR Management Consulting

CDD and Beneficial Ownership Update

By Diana Strade,Senior Associate Consultant
RLR Management Consulting, Inc.

The CDD and beneficial ownership rule finally went into effect and within days, FinCEN issues a ruling (FIN-2018-R002) to “provide exceptive relief to covered financial institutions from the obligations of the Beneficial Ownership requirements for Legal Entity Customers with respect to certain financial products and services that automatically roll over or renew (i.e. certificate of deposit (CD) or loan accounts) and were established before the Beneficial Ownership Rule’s applicability date, May 11, 2018. This exception begins, retroactively on May 11, 2018 and will expire on August 9, 2018.”

As a reminder, Customer Due Diligence-Overview and Examination Procedures was published in May 2018. Examiners will be using these procedures in regulatory examinations. It would be beneficial to review this document to ensure you are prepared.

We’re only days away from the deadline. Any thoughts on what FinCEN’s ruling will be regarding these products? Please weigh in, we’re interested in your thoughts on the subject.