Product Updates March 2026
The Product Updates for March 2026 from BankPolicies.com feature the following revised policy template products:
Bank Secrecy Act Policy Template – Comprehensive Version
Customer Identification Program Policy Template
The update to these products is in response to FinCEN Ruling FIN-2026-R001 entitled “Exceptive Relief from Requirement to Identify and Verify Beneficial Owners at Each Account Opening” dated 02/13/26 that granted exceptive relief to covered financial institutions from the requirements set forth in 31 C.F.R. § 1010.230(b) to identify and verify the identities of beneficial owners of legal entity customers at each new account opening. Rather than having to identify and verify a legal entity customer’s beneficial owners each time that customer opens an account, covered financial institutions may instead limit their identification and verification of the identities of beneficial owners under 31 C.F.R. § 1010.230(b) to the following circumstances:
- When a legal entity customer first opens an account with a covered financial institution;
- Any time thereafter when the covered financial institution has knowledge of facts that would reasonably call into question the reliability of beneficial ownership information previously obtained about the legal entity customer; and
- As needed based on a covered financial institution’s risk-based procedures for conducting ongoing customer due diligence.
Covered financial institutions must continue to comply with all other applicable anti- money laundering/countering the financing of terrorism (AML/CFT) requirements under the Bank Secrecy Act (BSA) and its implementing regulations, including program, recordkeeping, and reporting requirements.
The update to this product is in response to the U.S. District Court for the Middle District of Florida granted summary judgment to the CFPB, upholding its “Residential Property Assess Clean Energy Financing (Regulation Z)” final rule dated 12/17/24 against a trade group representing the residential PACE industry that sued the CFPB, citing concerns that the rule would adversely affect small businesses and alleging the rule exceeded the CFPB’s authority under Section 307 of the EGRRCPA, violated the Tenth Amendment, and failed to comply with procedural rulemaking requirements.
The court concluded that PACE financing meets TILA’s definition of “credit,” rejecting arguments that PACE assessments are taxes not subject to federal regulation and finding that Section 307 did not restrict application of other TILA provisions. It determined that the CFPB reasonably accounted for PACE’s “unique” characteristics, such as repayment through property tax bills and involvement of local governments, when applying ability-to-repay requirements.
The court also found the Bureau acted “within the zone of reasonableness” in relying on a report it created analyzing PACE transaction data that the CFPB had received from PACE companies and other sources, despite acknowledged data limitations. The court further held that the alleged noncompliance with small business review panel requirements under the Regulatory Flexibility Act was not subject to judicial review and that neither abridgment of taxing power nor “anticommandeering” concerns barred regulation of PACE financing as consumer credit under generally applicable federal lending standards. The ruling resolved the litigation on the merits ahead of the rule’s March 1, 2026, effective date.
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