I think FinCEN's Exceptive Relief from Beneficial Ownership Requirements for Legal Entity Customers of Rollovers, Renewals, Modifications, and Extensions of Certain Accounts Exceptive Relief (FIN-2018-R003), states it by saying that exceptive relief (i.e. no BO requirements) are granted for a renewal, modification, or extension of a loan (e.g., setting a later payoff date) that does not require underwriting review and approval.
I don't claim to be a lending compliance expert, but I believe where folks get tripped up is the definition of "underwriting." IMHO, FinCEN hints at that on page 3: "some loans are subject to automatic renewal, modification, or extension within a specified time and require no action from the customer for that renewal, modification, or extension to take effect."
So, for the above questions, my interpretation of FinCEN's ruling is:
- Loan Modification's require updated BO
- Deferments that don't change the terms in any way don't require updated BO and vice-versa
- LOC increases (past their limit) require updated BO
- Rates/Payment reductions require updated BO
But my stance is to err on the side of caution, so if there is a change in terms that requires some action from the customer and a review/approval from the FI, new BO is necessary. I'd be interested to hear other interpretations.