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