In my research of the beneficial owner requirement, I have not come across what time period constitutes a recertification. 30 days seems too soon to recertify if a customer whether new or existing. Is there a specific time in the FinCen rules? If not, what time period are most banks requiring recertification?

Thank you.

Subsequent account opening is what the regulation says. We are sticking to that.

The regulation does not use the term "recertification." No polite interval between certifications is assumed.

If an entity customer opens one account on Monday and a second on Tuesday, the requirement applies on both days. If your bank wants to go through some self designed abbreviation of the requirement, best of luck. However, you will find no support for pretending that it's too soon to ask for the same information a second time.

Has anyone had any push back from regulators yet regarding a short form attestation that nothing has changed with ownership upon opening a new account say, the following week?

All we have is Question #10 from the second FAQ document that was issued in April. That seems to allow for that kind of document.

Question 10: Identification and verification: Certification when a
single legal entity customer opens multiple accounts
If a legal entity customer opens multiple accounts at a covered financial institution
(whether or not simultaneously), must the financial institution identify and verify
the customer’s beneficial ownership for each account?

A. Generally, covered financial institutions must identify and verify the legal entity
customer’s beneficial ownership information for each new account opening,
regardless of the number of accounts opened or over a specific period of time.
However, an institution that has already obtained a Certification Form (or its
equivalent) for the beneficial owner(s) of the legal entity customer may rely on
that information to fulfill the beneficial ownership requirement for subsequent
accounts, provided the customer certifies or confirms (verbally or in writing) that
such information is up-to-date and accurate at the time each subsequent account
is opened and the financial institution has no knowledge of facts that would
reasonably call into question the reliability of such information. The institution
would also need to maintain a record of such certification or confirmation,
including for both verbal and written confirmations by the customer.