Q: In FinCEN’s exceptive relief related to rollovers, renewals, modifications and extensions, how do they describe safe deposit boxes?
A: In September, 2018, FinCEN issued a ruling that addressed exceptive relief from beneficial ownership requirements in specific situations. In part, the ruling included covered product descriptions and characteristics. For example, the following was included related to safe deposit boxes:
"Safe Deposit Boxes
Financial institutions maintain safe deposit boxes within their institutions that they rent to individuals and legal entities to store valuables such as collectibles, documents, and jewelry. While financial institutions do not have access to the contents of a safe deposit box rented to a customer, under the terms of the rental agreement, customers are not permitted to store money or dangerous substances in them. In exchange for the use of the safe deposit box, the customer generally pays a rental fee that is electronically deducted from an account provided to the financial institution. During the rental period, the financial institution has minimal or no communication with the customer, so long as the rental payment is made."