Decipher the acronym: FinCEN PPP CDD FAQs

Happy Monday! My husband and I are obsessed with HBO Max show, The Great Pottery Throw Down, so we decided to take a 10-week pottery class. It is a lot harder than it looks in the show, and I feel accomplished just making something that even vaguely resembles a pot.

On February 1, 2021 FinCEN released an update to their Paycheck Protection Program (PPP) Bank Secrecy Act (BSA) FAQs. The FinCEN guidance has also been included in the SBA’s Paycheck Protection Program Loans FAQs.

The original April FAQs provided guidance on the BSA requirement regarding customer due diligence (CDD), and how credit unions may meet their compliance obligations when issuing PPP loans. First, it clarified the PPP requirements to collect, certify, and verify beneficial ownership information. The guidance explained that if the credit union was lending to an existing member whose information was previously verified, the credit union was not required to re-verify the information.  The letter also clarified that if the credit union had not yet collected beneficial ownership information on the member applying for the PPP loan, the guidance would not require the credit union to collect the information, unless the credit union’s BSA compliance policy required collection of the beneficial ownership information.


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