Is there anything in the Beneficial Ownership rule that requires the Certification of Beneficial Owners be completed in person? Our loan department currently mails out renewals for existing legal entity customers to sign and we are wondering if we can complete the certification via mail as well.

It just has to be completed - there are no rules regarding where that happens.

Would it make sense to require that it be notarized if not completed in person? I feel like since there's no way to know if the information is accurate it doesn't really matter one way or another.

Not sure what a notarization would do for you. It just notarizes the signature and not the document contents.

We are not requiring notarization for the certification.

Thank you!

The whole Beneficial Ownership process is going to be a pain for unprepared representatives of legal entity customers. Adding a completely unnecessary notarization requirement will be pouring sale in the wounds.

Commenters suggested that FinCEN require a more meaningful promise than "Hey, as far as I know, these dudes own the company." They also suggested that the signature be notarized. FinCEN rejected both ideas.

Your examiners will suggest "enhancements" that increase the amount of wasted effort you put into this regulation. This will be one of them. Don't enhance your workload as a volunteer...