Department of Treasury, Washington, D.C. Credit/Adobe Stock
The Financial Crimes Enforcement Network (FinCEN) published its final beneficial ownership information (BOI) Access Rule on Dec. 22 and while officials at CUNA say they support the rule, the impact of the rule for credit unions has yet to be fully understood.
According to FinCEN, the final rule implements the BOI "access and safeguard provisions in the Corporate Transparency Act (CTA). The rule balances the statutory requirement to create a database of BOI that is highly useful to authorized BOI recipients, with the requirement to safeguard BOI from unauthorized use.
"This final rule reflects FinCEN's understanding of the critical need for the highest standard of security and confidentiality protocols to maintain confidence in the U.S. Government's ability to protect sensitive information while achieving the objective of the CTA noted above—establishing a database of BOI that will be highly useful in combatting illicit finance and the abuse of shell and front companies by criminals, corrupt officials, and other bad actors," the rule stated.
In a statement published Friday, Alexander Monterrubio, CUNA deputy chief advocacy officer for regulatory affairs said, "CUNA is highly supportive of the creation of the beneficial ownership database and hopes it will greatly ease meeting customer due diligence obligations under the Bank Secrecy Act (BSA) and its implementing regulations. The proposed permissible use of BOI obtained from the database was much too narrow. While we are still in the process of analyzing the final rule to fully understand its implications for credit unions, the rule does provide for a broader use of such information."
The final rule implements the provisions in the CTA that authorize certain recipients to receive disclosures of identifying information associated with reporting companies, their beneficial owners, and their company applicants. The CTA requires reporting companies to report BOI to FinCEN.
The BOI Access Rule goes into effect on Feb. 20, 2024.
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Michael Ogden
Editor-in-Chief at CU Times. To connect, email at [email protected]. As Editor-in-Chief of CU Times since 2016, Michael Ogden has led the editorial team in all aspects of content strategy and execution, including the creation of the publication’s exclusive and proprietary research database of the credit union industry’s economic landscape. Under Michael’s leadership, CU Times has successfully shifted to an all-digital editorial product with new focuses on the payments, fraud, lending and regulatory beats. Most recently, he introduced a data-focused editorial product for subscribers that breaks down credit union issues into hard data, allowing for a deeper and more factual narrative for readers. In 2024, he launched the "Shared Accounts With CU Times" podcast, which offers a fresh, inside-the-newsroom perspective through interviews with leaders from the credit union industry and the regulatory world. He dives into pressing credit union issues, while revealing the personalities working behind-the-scenes to push the credit union world forward. His background includes years as a radio and TV anchor/reporter and a public relations and digital/social media manager, where he covered the food and music industries, as well as cooperatives and credit unions. Over the years, he has launched numerous exclusive video and podcast series, including a successful series of interactive backstage interviews with musicians at music festivals, showcasing his social media and live streaming production skills.
