We're considering the use of a Beneficial Ownership Recertification (short-form) for when additional accounts are opened for the legal entity customer after the original (full-size) Certification is obtained. Anyone else toying with this? Thoughts/comments?

No, we are only going to use the original full-size form when a new account is opened.

I was unaware of any such beast. Please share and I will let you know if we will be using it or not.

Hi, Rock. Don't have one developed yet, but envision the mini-form would include the legal entity name/type, and the name, title and signature of the individual certifying that the beneficial ownership information on file with the [bank] is complete and correct. Per our core vendor, we will be able to enter all beneficial ownership data in our CIF database where it will be accessible as subsequent accounts are opened. It would be up to front-facing staff to review the B/O information with the person completing the certification. Obviously, if any information had changed, we'd revert to the full certification.

My initial thought is that such a recert form may be appropriate for an account renewal, but I am not sure I'd feel comfortable about using such a practice on subsequent new accounts since the certification requirement is at the account level, not the relationship level.

Sorry, but I'm skeptical.

First, obtaining the certification is like taking a shower, it doesn't make any difference that you took one yesterday or last month. Calling it a "reshower" could only falsely imply that it's of lesser importance because you have done it once or twice before.

Second, if FinCEN had followed the structural model used by the FRB in their regulations and listed the required contents of the certification in the regulation and then showed Appendix A as a compliant example, we would all know what is required and what is not. They did not. Any deviation from one of the two samples published by FinCEN will test an examiner's tolerance for flexibility. Some don't have any, particularly when they are feeling their way around a new regulation.