If someone opens a safe deposit box that the annual fee is automatically debited from their account I believe you could treat that as a renewal and have them sign to notify you of any future changes in beneficial ownership at time of opening. What about the customers who pay by check? Can you treat them as if they will auto renew or must you re-certify each year?

FinCEN has not said that allowing continued access to a safe deposit box because of a rent payment is a new account, and I would be very reluctant to suggest that it might be. A safe deposit box lease agreement is the equivalent of a "month-to-month" apartment rental. You keep paying the rent and your key continues to work. For the box, you keep paying the rent and you get access for the next billing period. It's not a new account.

Ok, that's good. Someone from a seminar had said to treat them as renewals and I hadn't read or understood that before. Thanks.