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#2208324 - 03/08/19 10:09 PM SDB and BOC
overregulated Offline
Junior Member
Joined: Sep 2005
Posts: 42
During a discussion with an auditor, he stated that we needed a Beneficial Ownership Certification every year our Safe Deposit Boxes renew. This is due to missing verbiage (customers are not permitted to store money or dangerous substances in them) in our SDB agreement. Our safe deposit boxes are continual as long as the customer pays. Has anyone else heard of this?

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#2208335 - 03/09/19 06:20 AM Re: SDB and BOC overregulated
BrianC Offline
Power Poster
Joined: Nov 2004
Posts: 6,240
Refer your auditor to FinCen’s exceptive relief published in September 2018 which specifically excludes safe deposit box renewals. Get is once at the time the box is leased and you are done unless the legal entity subsequently leases a new box or you acquire knowledge that there is a change in ownership.
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!

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