FinCEN recently issued an Exceptive Relief granting financial institutions an exception “for 90 days, up to and including August 9, 2018, from the Beneficial Ownership Rule’s requirements to identify and verify beneficial ownership information for rollover or renewal of certain financial products and services (i.e., CD and loan accounts) that were established before May 11, 2016.” This exception begins, retroactively, on May 11, 2018.  FIN-2018-R002 was issued with the information.

In the meantime, FinCEN will determine whether and to what extent additional exceptive relief may be appropriate for such financial products and services “that were established prior to May 11, 2016, but are expected to rollover or renew after such date.”

FinCEN clarified in the April 3, 2018 CDD FAQs that financial institutions are required to obtain beneficial owner information for legal entities each time the member opens a new account, even for existing members.