I would hope that the regulations under the Corporate Transparency Act will call for certification and updating to be a function handled by FinCEN and the entities, and banks' involvement will be verification of ownership against the FinCEN database.
"If wishes were horses, beggars would ride."
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8