Beneficial Ownership Basics

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CE Credits: 1.25 CRCM


The Corporate Transparency Act (CTA) became law on January 1, 2021 as part of the National Defense Appropriations Act. 31 USC 5336. The CTA requires FinCEN to promulgate regulations that prescribe procedures and standards for the reporting, access, and use of beneficial ownership information. FinCEN has taken a phased rulemaking approach, breaking down the regulations into three separate phases: 1) the Reporting Rule; 2) the Access Rule; and 3) the Conforming Rule. The Reporting Rule was finalized in September 2020 and became effective on January 1, 2024. 87 FR 59498. The Reporting Rule dictates the requirements for certain companies to report beneficial ownership information to FinCEN’s Beneficial Ownership Secure System (BOSS). The Access Rule was finalized in December 2023 and became effective on February 20, 2024. 88 FR 88732. The Access Rule prescribes the rules for access to, and use of, the beneficial ownership information contained within the database. The Conforming Rule is expected to be proposed sometime in 2024 and will modify the Customer Due Diligence (CDD) rules for banks. This webinar reviews the history and purpose of the Beneficial Ownership rules, provides an overview of the Corporate Transparency Act (CTA), discusses minor effects the Reporting and Access Rules may have on banks, and contemplates the expected effects of the Conforming Rule based on the information we have so far. We’ll also review current supervisory expectations, potential key changes for BSA/AML programs and procedures, and several frequently asked questions.

Key Takeaways:

    1. Beneficial Ownership History and Purpose

    1. Overview of Corporate Transparency Act

    1. Brief Discussion of Reporting Rule

    1. Brief Discussion of Access Rule

    1. Expectations of Conforming Rule

    1. Action Items for Bank

People Who Should Attend: 

All C/A members and their personnel are welcome to attend this webinar. We especially recommend the attendance of key personnel involved in BSA/AML compliance, including Senior Management, Compliance Officer(s), Deposit and Lending Officers, Business Relationship Bankers, and any other personnel who are involved in strategic planning, change management, and information systems and data collection/maintenance/reporting.

Presenter: Theo Kelly, JD
VP and Associate General Counsel

Theodore Kelly serves as VP and Associate General Counsel for Compliance Alliance. He holds a Bachelor’s Degree in Political Science from The Ohio State University, a Master’s in Business Administration from Franklin University, and a Juris Doctor from Capital University Law School. Theo began his professional career serving in the United States Marine Corps in communications security and, later, the Ohio Army National Guard as a Military Police Platoon Leader. More recently, Theo served as first-line of defense at the largest bank in the world from 2015 – 2017 and led Ethics & Compliance operations at a Texas-based Fortune 500 company from 2017 – 2021.

Theo’s professional pursuits include competently guiding business leaders in all matters of regulatory compliance, learning and sharing ways in which blockchain technology can positively impact business operations, and writing publications related to emerging technologies in the legal, risk, and compliance spaces. For B/A, he will be writing monthly for our various publications, including ACCESS magazine.