Instructions, guidance on BOI requests needed as soon as possible

The Beneficial Ownership Information (BOI) database established under the Corporate Transparency Act (CTA) should provide significant and important relief for credit unions from the Financial Crimes Enforcement Network’s (FinCEN) customer due diligence (CDD) requirements, America’s Credit Unions wrote Friday. Comments were sent in response to FinCEN’s proposed information collection regarding BOI requests.

America’s Credit Unions’ Luke Martone urged FinCEN to release such instructions and guidance on the form and manner of BOI requests as soon as possible.

“Although credit unions and other financial institutions will not have access to the database until later this year, it is important that they have detailed information on the process now in order to make any necessary system updates and train staff,” Martone wrote, calling for development of rules in a way that allows credit unions and other financial institutions to comply as efficiently as possible.

“Any opportunity to avoid a manual data input function, particularly on a back-office compliance team that might already be under-resourced, could significantly reduce the compliance burden on credit unions,” Martone said.

Martone also encouraged FinCEN to work with the financial institutions that will be accessing the BOI database on a regular basis to “better understand where pain points may exist” and update the process as appropriate.”

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