FinCEN issues correction to May 16 ruling

On May 16, 2018, FinCEN issued Administrative Ruling FIN-2018-R002, "Beneficial Ownership Requirements for Legal Entity Customers of Certain Financial Products and Services with Automatic Rollovers or Renewals," to provide a 90-day limited exceptive relief from the obligations of the Beneficial Ownership rule with respect to certain financial products and services that automatically rollover of renew (certificates of deposit or loan accounts). On May 22, FinCEN announced a correction to the last paragraph of the Administrative Ruling, where the rules applicability date was incorrectly given. The date has been corrected to May 11, 2018. The revised version of FIN-2018-A002 is available on FinCEN's website.

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).