FinCEN delays Beneficial Ownership rule for rollovers and renewals

On Wednesday, five days after the effective date of its Beneficial Ownership Requirements rule, FinCEN issued Administrative Ruling 2018-R002, granting a 90-day limited exceptive relief to covered financial institutions with respect to certificates of deposit and loan accounts that automatically roll over or renew that were established before May 11, 2018. The 90-day relief period started on May 11 and will end on August 9, 2018. The ruling says that, during this time, "FinCEN will determine whether and to what extent additional exceptive relief may be appropriate for such financial products and services that were established before May 11, 2018, but are expected to rollover [sic.] or renew after such date."

Editor's Note: The "exceptive relief" provided by FIN-2018-R002 extends only to certificates of deposit and loans that automatically rollover or renew. Loan renewals that are not automatic are not covered, and currently are subject to Beneficial Ownership requirements. They are covered, however, by Question 12 in FinCEN's April 3, 2018, Guidance FAQs (FIN-2018-G001).