SDB and BOC

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?

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.