Within one year of the effective date of the rule, FinCEN will be required to rescind much of the identification and verification requirements under the current customer due diligence (CDD) rules; however, the general requirement for financial institutions to identify and verify beneficial owners would be retained. In addition, other rulemakings are expected with respect to who may access the BOI, for which purposes it may be accessed, and safeguards to ensure the information maintained is secured and protected. BOI IMPACT ON FINANCIAL INSTITUTIONS For the time being, financial institutions must continue to collect BOI in the same manner they’ve followed since 2018; however, additional rulings are expected within the year that could change those requirements. For now, financial institutions should practice business as usual with respect to the collection of BOI while, at the same time, staying alert for proposed revisions to the customer due diligence rule and the opportunity to provide commentary. (406) 604-4540 NeighborWorks Montana and our network of partners across the state provide homebuyer education and counseling, creating successful, mortgage-ready homebuyers. Reach out today to find out how we can help your buyers be the most successful homebuyers possible! nwmt.org info@nwmt.org mibonline.org 21
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