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TCH Comments on FinCEN’s Customer Due Diligence Proposal

The Clearing House Association submitted a letter to FinCEN on customer due diligence (CDD) requirements for financial institutions. The letter supports the concept of having a single regulation setting out banks’ CDD requirements, but points out a number of issues with FinCEN’s proposal, especially in the sections proposing a blanket requirement to identify and, in some cases, verify the beneficial owners of corporate accounts.