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FinCEN sets Dec. 3 due diligence discussion
WASHINGTON (11/14/12)--The Financial Crimes Enforcement Network (FinCEN) will host a fifth and final roundtable discussion on proposed consumer due diligence (CDD) regulations that would require financial institutions and others to establish and maintain member and customer account monitoring policies.

The FinCEN roundtable will take place on Dec. 3 at the Miami Branch of the Federal Reserve Bank of Atlanta. The meeting will consist of two separate three-hour sessions. The first session will start at 9:30 am ET, and the second session will begin at 1:30 pm ET. FinCEN said advanced registration is required.

Discussion will focus on FinCEN's March Advanced Notice of Proposed Rulemaking that would codify, clarify, consolidate and strengthen CDD rules. The CDD proposal, which would apply to financial institutions, securities brokers and dealers, mutual fund brokers and dealers, futures commission merchants, and some introducing commodities brokers, addresses standards for verifying the identity of each member/customer and understanding the "nature and purpose" of each account held at an institution to assess the likelihood of suspicious activity.

The FinCEN plan, if made final, would be one part of a broader U.S. Treasury strategy to enhance financial transparency in order to strengthen efforts to combat financial crime, including money laundering, terrorist financing, and tax evasion.

How and when financial institutions collect "beneficial ownership" information from their customers and members, and how this information is verified, will be discussed during the meeting. FinCEN is also interested in any costs associated with obtaining this information. Roundtable attendees will also have the chance to discuss how they conduct due diligence on trust accounts, and how financial institutions identify whether their customers are or are not "shell companies."

The Credit Union National Association (CUNA) supports the objectives of the FinCEN proposal, but noted the burdens and costs credit unions could face as a result would far outweigh the purported benefits to FinCEN. CUNA has suggested that FinCEN abandon the due diligence proposal and, alternatively, work with the National Credit Union Administration and other federal financial regulators to further clarify current Bank Secrecy Act and anti-money laundering rules.

For more on the FinCEN meeting, use the resource link.
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