
The beneficial ownership information (“BOI”) registry under the Corporate Transparency Act (“CTA”) is now up and running at the Financial Crimes Enforcement Network (“FinCEN”). This post will follow up on a previous blog regarding the recently-published CTA BOI access regulations (the “Access Rule”). As we will discuss, the Access Rule leaves open many important questions for financial institutions (“FIs”) covered by the CTA, as they await further proposed regulations from FinCEN regarding alignment of the CTA with the Customer Due Diligence (“CDD”) Rule.
The full federal register publication for the Access Rule is here. It is 82 pages long. We therefore have created this separate 13-page document, which is slightly more user-friendly, setting forth only the actual regulations (now published at 31 C.F.R. § 1010.955).
Continue Reading Final CTA Access Rule Answers Some Questions, and Leaves Open Others