Removing Barriers Blog

CUNA Makes Recommendations to FinCEN on Design of Beneficial Ownership Database
Posted May 05, 2021 by CUNA Advocacy

CUNA filed comments with the Financial Crimes Enforcement Network (FinCEN) in response to an advance notice of proposed rulemaking (ANPRM). In the ANPRM, FinCEN requested information regarding the requirements for the new beneficial ownership information database required by the Corporate Transparency Act (CTA). The CTA requires that certain legal entities report their beneficial ownership information directly to FinCEN, which will then disseminate that information to authorized users, including credit unions meeting their customer due diligence (CDD) requirements. In its comment to the ANPRM, CUNA recommends that FinCEN design the database to permit credit unions and other financial institutions to obtain information on-demand with the legal entity customer’s consent. CUNA also recommended that any definitions and required information in the database align with the CDD requirements to ensure credit unions are able to meet these requirements without accessing additional information. The ANPRM is just the first exciting step in building-out the database, which will not be available for credit union use for a few years.