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The Financial Crimes Enforcement Network (FinCEN) yesterday issued a limited 90-day exemption to covered financial institutions from obligations under its customer due diligence (CDD) rule, which went into effect Friday. The exemptions pertain to the rule's beneficial ownership requirements and certain products that automatically rollover and renew.

The exemption expires Aug. 9. Specifically, products and services that automatically rollover and renew and were established before the rule's compliance date – such as certificates of deposit or loan accounts – are exempt.

The CDD rule requires credit unions to identify and verify the beneficial owner(s) of legal entity accounts, subject to certain exceptions. Previously, a credit union was only required to know the identity of each of its legal entity customers but not necessarily its beneficial, natural person owners.

Beneficial owners include each natural person who directly or indirectly has a 25 percent or more equity interest in the legal entity customer, as well as individuals that have "significant responsibility to control, manage or direct a legal entity customer," such as a CEO, COO or CFO.

NAFCU has a host of resources available, including a webinar, to help credit unions comply with the rule.

Last month, NAFCU met with FinCEN to share the credit union perspective on regulations under the Bank Secrecy Act (BSA) and impending CDD rule in an effort to improve the industry's regulatory environment. NAFCU's recently released BSA Blast e-newsletter also provides detailed explanations on some of the questions NAFCU has received related to the CDD rule. Other resources related to the rule, including FinCEN's first and second sets of interpretive guidance, is also available in the e-newsletter.

Also in April, FinCEN issued an updated FAQ document to help financial institutions better understand the scope of its CDD final rule.

NAFCU has additional compliance resources, including a recent blog post, on the CDD rule available here.