[Barb]

Because of this exception and the way I understood it, we were going to delay getting the beneficial ownership information on our renewing loans during this time. I just read an article that stated that unless the loan would automatically renew this exception would not apply. We do an extension/modification to renew a loan – it doesn’t automatically renew without paperwork being completed.

What’s your interpretation of this?

[susan costonis]

It’s difficult to comment on the author’s position about loss of the automatic renewal exception without seeing the same article. I recommend that you ask your primary regulator for additional guidance.

[NLD7319]

Unless your loans “automatically” renew, I do not believe the relief applies. Most loan renewals require a credit review before the loan is renewed. I’ve read several articles on this and that appears to be the consensus. This is yet another example of how FinCEN is out of touch with how things are done. It never hurts to contact your regulator for their interpretation though.

[Author]

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