With less than two weeks remaining before the Treasury’s Financial Crimes Enforcement Network’s (FinCEN) customer due diligence (CDD) becomes effective May 11, FinCEN has made its electronic CDD beneficial owner certification form available.
There is no requirement that covered financial institutions use the certification form. Rather, FinCEN provides the optional form for the convenience of covered financial institutions as one possible method to obtain the required beneficial ownership information.
Financial institutions may choose to comply with the requirements of the CDD rule by using another method, such as through the institutions’ own forms, or any other means that comply with the requirements of this obligation.
Financial institutions should make a copy of the certification form and retain it. It should not be sent to FinCEN.
The form is available in PDF and Microsoft Word versions. The Word version should be printed out and completed, while the PDF version can be filled out electronically then printed out.
Additional details on the certification form can be found in Question 8 of FinCEN’s recent FAQ document.
Additional information about the CDD rule’s requirements can be found on CUNA’s CompBlog.