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#2178536 - 05/17/18 03:32 PM temporary exception to CDD and CD and Loan renewal
JennKK2 Offline
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Joined: Nov 2006
Posts: 318
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so wow!
what can we actually expect FINCEN to determine after these 90 days - is it more than likely they will keep the initial ruling the same or can we honestly expect changes in regards to renewals?
I can see CD being the lessor of two evils but loans, not so much.
can't wait for comments!!
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#2178537 - 05/17/18 03:33 PM Re: temporary exception to CDD and CD and Loan renewal JennKK2
Elwood P. Dowd Offline
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Elwood P. Dowd
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#2178547 - 05/17/18 04:05 PM Re: temporary exception to CDD and CD and Loan renewal JennKK2
Victoria S Offline
Member
Joined: Jul 2015
Posts: 96
I'm confused. Does this apply to renewals of cds opened prior to 5-11-18 or 5-11-16??

The ruling states the following:The Financial Crimes Enforcement Network (FinCEN) is issuing this ruling to provide a 90-day limited exceptive relief to covered financial institutions from the obligations of the Beneficial Ownership Requirements for Legal Entity Customers (31 CFR § 1010.230) (Beneficial Ownership Rule) with respect to certain financial products and services that automatically rollover 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.

For the reasons discussed above, FinCEN grants an exception to covered financial
institutions for 90 days, up to and including August 9, 2018, from the Beneficial
Ownership Rule’s requirements to identify and verify beneficial ownership
information for rollover or renewal of certain financial products and services ( i.e.,
CD and loan accounts) that were established before May 11, 2016

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#2178549 - 05/17/18 04:09 PM Re: temporary exception to CDD and CD and Loan renewal Victoria S
Victoria S Offline
Member
Joined: Jul 2015
Posts: 96
Ok, I see another reply where the 5-11-16 must've been a typo.

Thanks.

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