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Case Detail


In re: Customer Due Diligence Requirements for Financial Institutions
On October 3, 2014, WLF filed formal comments with the Financial Crimes Enforcement Network, encouraging the agency to abandon a rule that would require financial institutions to collect highly sensitive information, including the date of birth and social security number, for each beneficial owner of a legal entity opening a new account. WLF expressed concern that this requirement would disproportionately affect small and closely-held business owners because the proposed rule excludes publicly-traded companies from divulging even the names of their beneficial owners. WLF explained that requiring the individual owners of small and closely-held companies to provide such sensitive information increases the risk that they will become victims of identity theft. WLF also cautioned that the proposed rule would force financial institutions to engage in conduct that would expose them to even greater liability from the FTC if their secured networks are ever breached.
Case Status:
Awaiting agency response.
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