SBA / Treasury FAQ – 18. Are PPP loans for existing customers considered new accounts for FinCEN Rule CDD purposes?

Compliance > CARES Act
Q:  Are PPP loans for existing customers considered new accounts for FinCEN Rule CDD purposes? Are lenders required to collect, certify, or verify beneficial ownership information in accordance with the rule requirements for existing customers?
 
A:  If the PPP loan is being made to an existing customer and the necessary information was previously verified, you do not need to re-verify the information. Furthermore, if federally insured depository institutions and federally insured credit unions eligible to participate in the PPP program have not yet collected beneficial ownership information on existing customers, such institutions do not need to collect and verify beneficial ownership information for those customers applying for new PPP loans, unless otherwise indicated by the lender’s risk-based approach to BSA compliance.
 
 

This Q&A was based on information contained from the Treasury Department’s April 2020 issuance “Paycheck Protection Program Loans, Frequently Asked Questions,” which has been updated from time to time.  This CARES Act / SBA / PPP related issuance may be found here:  https://home.treasury.gov/system/files/136/Paycheck-Protection-Program-Frequently-Asked-Questions.pdf

 

Add Feedback