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FinCEN's interim rule narrowing the Corporate Transparency Act's beneficial-ownership reporting to foreign-formed entities remains in force. Domestic companies and their U.S. owners are, for now, outside the BOI reporting regime. That is a meaningful contraction from the original rule's sweep of millions of small businesses.
For a bank, the change is less about who files with FinCEN and more about what your own customer due-diligence procedures assume. Manuals written to the original scope now over-reach, and manuals written before the CTA under-reach. Either way, the document an examiner opens should match the rule as it stands today.
What changed
| Original CTA scope | Interim scope · in force | |
|---|---|---|
| Covered entities | All domestic reporting companies | Foreign-formed entities only |
| U.S. beneficial owners | U.S. beneficial owners reported | U.S. persons exempt from reporting |
| Filer population | ~32M entities in initial estimate | Sharp reduction in covered filers |
A narrower rule is a different obligation, even if it is not a lighter one. Your procedures have to name it.
Re-papering your CDD
The beneficial-ownership rule for banks' own customers is distinct from the CTA filing regime, but examiners will expect your program to reflect the current legal landscape coherently. Treat the items below as a documentation pass. They do not call for a system overhaul.
- Update the scope language. State the interim foreign-entity scope explicitly in your CDD/BOI procedures, with the effective date.
- Reconcile customer onboarding. Confirm your account-opening forms and CIP flows still collect what the bank rule requires, independent of CTA.
- Brief frontline staff. Make sure tellers and lenders are not citing the superseded broad-scope guidance to customers.
- Log the change. Record the procedure revision in your BSA committee minutes so the timeline is auditable.
Zovos diffs your live CDD manual against the current rule text and drafts the redline. Re-papering becomes a review instead of a rewrite.
This is for information only and is not legal advice. Confirm your obligations against the current rule and counsel before acting.