On May 5, 2016 FinCEN issued its final rule on beneficial ownership and customer due diligence.  This rule was issued to strengthen customer due diligence requirements for covered institutions.  The rule included a new requirement to identify and verify the identities of beneficial owners of legal entity customers (LEC).  A beneficial owner was deemed as any individual who owns 25 percent or more of the equity interests of a LEC and a single individual with significant responsibility to control, manage, or direct a LEC.
Upon issuance of the final rule, a mandatory compliance date of May 11, 2018 was set.  As the deadline approaches, Compliance Resource felt it was necessary for us to tackle the topic once more for our Compliance Masters Group (CMG) as well as for those of you outside of the group.  In advance of a recent session, we solicited responses to a survey from members of our CMG on the implementation of the new rule.
The survey covers many questions that can give you an idea of the progress other financial institutions have made in implementing their new policies and procedures.  For example, 23% of respondents have purchased or are developing new tools to assist them, while 90% have tools built within their existing systems.  In addition, nearly 70% anticipate that the beneficial ownership determination will add approximately 10-15 minutes to account opening.
To review all 14 questions, you can download the full survey results
You can also register for our April 9th webinar w/Susan Costonis – Critical CDD Changes for Beneficial Ownership Rules – Are You Prepared for May, 11, 2018?