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Financial Services Law Insights and Observations

FinCEN Extends Proposed Customer Due Diligence Program Comment Period, Issues Electronic Filing Reminder

FinCEN Bank Secrecy Act

Consumer Finance

On May 4, FinCEN extended the comment period for its proposal to establish a customer due diligence regulation that would require covered financial institutions to institute defined programs to identify the real or beneficial owners of customer accounts. The proposed regulation is designed to enhance federal anti-money laundering and counterterrorism efforts. Interested parties will have an additional thirty days to comment from the time the extension is published in the Federal Register.  On May 7, FinCEN reminded financial institutions subject to the Bank Secrecy Act that certain BSA-required filings must be filed electronically beginning July 1, 2012.