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ARTICLE · 07 MARCH 2012

Financial Services Alert – March 6, 2012

On February 29, 2012, the Financial Crimes Enforcement Network ("FinCEN") issued an advanced notice of proposed rulemaking (the "Advance Notice") in which it sought comment on a proposal to expressly require that financial institutions conduct customer due diligence ("CDD"), including by collecting beneficial ownership information for all customers, with limited exceptions.

United StatesFinance and Banking

Developments of Note

  • FinCEN Seeks Comment on Proposal to Require Banks, Brokers, Dealers, Mutual Funds and Certain Other Financial Institutions to Establish Customer Due Diligence Programs
  • FINRA Requests Comment on Revised Rule Proposal to Address Conflicts of Interest Related to Debt Research Reports
  • SEC and CFTC Propose Rules to Address FCRA Requirements regarding Identity Theft Programs and Credit Card Changes of Address

Other Items of Note

  • FinCEN Issues Advisory to Internal and External Counsel of Financial Institutions Reminding Them That They Must Maintain Confidentiality of SARs
  • FRB Extends Comment Period on Proposed Rule for the Supervision and Regulation of Large Bank Holding Companies and Systemically Important Nonbank Financial Firms

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