BPI Comments on FinCEN’s Renewal of CDD Beneficial Ownership Requirements

On February 28, BPI submitted comments to the Financial Crimes Enforcement Network (FinCEN) on its Paperwork Reduction Act notice to renew without changing its beneficial ownership information collection requirements for legal entity customers under the Customer Due Diligence (CDD) rule. The letter argues that FinCEN’s burden estimate for this requirement significantly underestimates the actual time it takes banks to collect, update, and maintain beneficial ownership information for legal entity customers and, in many cases, fails to account for barriers to information collection. The letter further encourages FinCEN to address the undue burden placed on financial institutions by establishing beneficial ownership collection and certification expectations at the legal entity level, with recollection required on a risk-basis.