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Comp Blog

After more than 2 years, the CDD proposal is finally out for comment

By: Danielle Wright

CommentThursday - July 31, 2014

Although the potentially burdensome customer due diligence (CDD) regulation is moving forward, we aren’t expecting to see a compliance date anytime soon. FinCEN is currently recommending an effective date one year after the final rule is issued.

It’s FinCEN’s position that CDD consists, at a minimum, of four elements:

  1. Identifying and verifying the identity of credit union members;
  2. Identifying and verifying the identity of beneficial owners of legal entity members;
  3. Understanding the nature and purpose of member relationships; and
  4. Conducting ongoing monitoring to maintain and update member information and identify and report suspicious activity.

This proposed regulation may have a significant impact on your BSA compliance.  This is your opportunity to influence the final compliance requirements.  Comments are due in early October. For more information on the comment process go to cuna.org/powercomment.






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