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5/3/18 - Cynthia Shea on the Challenges Posed by Fincen’s CDD Rule

Promontory Director Cynthia Shea was quoted in an American Banker article about the incorporation of stress testing into the Federal Reserve’s new proposed rating system given its significance since the financial crisis.

Shea commented specifically on the challenges posed to banks by the Financial Crimes Enforcement Network’s rule for customer due diligence.

“We’re watching the CDD rule because we’ve seen some problems with early implementation. Banks are having difficulty developing the information on ownership and control, particularly with the requirement to obtain certification from the people opening the accounts," Shea said. "Banks won’t be able to develop the information from legitimate third-party sources, and there are significant hurdles to establishing the policy for all customers, including established accounts.”

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