U.S. Chamber Comments to FinCEN on Beneficial Ownership Information Access and Safeguards

The U.S. Chamber of Commerce (“the Chamber”) appreciates the opportunity to share our views in response to the Financial Crimes Enforcement Network’s (“FinCEN”) notice of proposed rulemaking (“NPRM”) on “Beneficial Ownership Information Access and Safeguards, and Use of FinCEN Identifiers for Entities” (“Proposed Rule”) under the Corporate Transparency Act (“CTA” or “Act”). The Proposed Rule is the second of three rulemakings and “would implement the provisions in the CTA, codified at 31 U.S.C. 5336(c), that authorize certain recipients to receive disclosures of identifying information associated with reporting companies, their beneficial owners, and their company applicants (together, BOI).”It follows FinCEN’s rule on Beneficial Ownership Information Reporting Requirements, which was finalized on September 30, 2022 and focuses exclusively on the Act’s beneficial ownership reporting requirements. The third and final rulemaking will seek to revise the existing Customer Due Diligence Rule (CDD) as needed.