I would love to hear others' interpretation of what in holy H3!! is going on in this FAQ (second part of #2 on FinCEN's version) dated 4/13/2020:
"For lenders with new customers: For new customers, the lender’s collection of the following information from all natural persons with a 20% or greater ownership stake in the applicant business will be deemed to satisfy applicable BSA requirements and FinCEN regulations governing the collection of beneficial ownership information: owner name, title, ownership %, TIN, address, and date of birth. If any ownership interest of 20% or greater in the applicant business belongs to a business or other legal entity, lenders will need to collect appropriate beneficial ownership information for that entity. If you have questions about requirements related to beneficial ownership, go to https://www.fincen.gov/resources/statutes-and-regulations/cdd-final-rule.
Decisions regarding further verification of beneficial ownership information collected from new customers should be made pursuant to the lender’s risk-based approach to BSA compliance."
Here is my interpretation: For new customers, we can use the information collected on the PPP application (if the application asks for all of the information - name, title, ownership %, TIN, address, and DOB) and not require the separate Beneficial Ownership form as described in the CDD Final Rule nor do we have to verify the identity of the individuals. BUT, and this is where I get thrown off the rails, IF the applicant entity is owned 20% or more by another entity, we then have to get the Beneficial Ownership form completed, NOT for the applicant entity but for the entity(s) who own the applicant entity?
Am I understanding correctly? If so, it's like they've rewritten the CDD Rule mid-stream and it's nothing like what is already in place. I really hope that I'm way off base.