The Certification Form in Appendix A of the beneficial ownership final rule does not include this language. However, as you pointed out, FinCEN’s subsequent FAQs permit banks to comply with the beneficial ownership rule requirements for account renewals by adding this “notification” language to the legal entity customer’s certification at the time of the first renewal after May 11, 2018.

If you are copying, downloading, or using software that produces the voluntary Certification Form in Appendix A, we recommend adding an addendum on a separate page that tracks the language in the FAQ — requiring the customer to “agree to notify the financial institution of any change in such information.” If your bank uses its own beneficial ownership certification form, your bank may wish to add this language directly within that form, rather than including it on a separate addendum.

For resources related to our guidance, please see:

• Final Rule, Customer Due Diligence Requirements for Financial Institutions, 81 Fed. Reg. 29397 (May 11, 2016) 

• FIN-2018-G001 — FAQs Regarding Customer Due Diligence Requirements for Financial Institutions (April 3, 2018) (Question 12: “Are financial institutions required to have their legal entity customers certify the beneficial owners for existing customers during the course of a financial product renewal (e.g., a loan renewal or certificate of deposit)? A. Yes. Consistent with the definition of ‘account’ in the CIP rules and subsequent interagency guidance, each time a loan is renewed or a certificate of deposit is rolled over, the bank establishes another formal banking relationship and a new account is established. Covered financial institutions are required to obtain information on the beneficial owners of a legal entity that opens a new account, meaning (in the case of a bank) for each new formal banking relationship established, even if the legal entity is an existing customer. For financial services or products established before May 11, 2018, covered financial institutions must obtain certified beneficial ownership information of the legal entity customers of such products and services at the time of the first renewal following that date. At the time of each subsequent renewal, to the extent that the legal entity customer and the financial service or product (e.g., loan or CD) remains the same, the customer certifies or confirms that the beneficial ownership information previously obtained is accurate and up-to-date, and the institution has no knowledge of facts that would reasonably call into question the reliability of the information, the financial institution would not be required to collect the beneficial ownership information again. In the case of a loan renewal or CD rollover, because we understand that these products are not generally treated as new accounts by the industry and the risk of money laundering is very low, if at the time the customer certifies its beneficial ownership information, it also agrees to notify the financial institution of any change in such information, such agreement can be considered the certification or confirmation from the customer and should be documented and maintained as such, so long as the loan or CD is outstanding.”)

• Optional Certification Form in Appendix A of the CDD Rule