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6 Action Items For Customer Communication Around Beneficial Ownership

February 13, 2018
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Customer Communication Around Beneficial Ownership

Set Expectations With These Tips on Customer Communication Around Beneficial Ownership

We all know the mandatory compliance date for the CDD Rule is approaching. Banker’s Toolbox has stressed the importance of updating your processes and procedures, training your staff and making sure you have the right solutions in place to capture and store beneficial ownership information. However, you don’t want to drop the ball on spending the time and resources to educate your customers/members on changes they can expect to see as a result of the CDD Rule.

Since there will be significant changes in the account opening process, it is important for your institution to be proactive and communicate these changes as early as possible. Educating your customers about the new regulation will make the account opening process easier for your staff, and reiterate that they will encounter these changes at all institutions, not just yours. Knowing this information ahead of time will provide a positive customer experience and provide a strong foundation for a long-lasting relationship.

We have compiled a list of six things you can do to be proactive in educating your customers about the changes they will see as a result of the CDD Rule. Remember, like any good relationship, communication is key.

  1. Website

Create a banner on your website and that notifies your customers of the coming changes as soon as possible. Work with your marketing team to make the banner interesting and informational. Link the website banner to the regulation or a FAQ page on your website. Don’t be afraid to use FinCEN as a resource! The bulletin on FinCEN’s website clearly explains the new account opening process and what information will be required from customers before they open a new account. In addition to creating a website banner, it is important to update the information on your account opening page to reflect the new requirements for opening an account.

  1. Email

Send out email communication to all customers. This will allow you to reach a large audience with one announcement. Draft the email to focus on the regulatory changes, rather than a change in your institution’s policies. This will build rapport with your customers, as they will appreciate the forward thinking.

  1. Social Media

Just in case your customers haven’t seen your website announcement or the email you sent, it’s always good idea to use the power of social media. Create cover photos/banners to help with the message, as well as posting regularly. Be sure to link your posts back to your institution’s website or FinCEN’s Beneficial Ownership resources.

  1. Front Line

Your frontline staff are the faces your customers know and trust. Be sure to arm your front line with the training and resources they need to answer customer questions on the regulatory changes. Work with your marketing team to create a brochure or FAQs one-sheet, explaining the upcoming changes that accompany Beneficial Ownership and how it may affect them. Whenever possible provide an in-person, interactive training to give your frontline staff an opportunity to ask questions.

Arming your frontline staff with the resources they need to be successful in gathering beneficial ownership information, will make your job as a BSA Officer much easier. Due Diligence Manager, by Banker’s Toolbox, provides a customizable questionnaire that works as a teller system that will walk your frontline through the new account opening process. This will make it easy for them to collect the information needed and allow them to focus on questions that are relevant to the customer.

  1. FinCEN Cover Letter (Appendix A)

Use the cover letter in Appendix A of the regulation. The verbiage in the cover letter can help you create customer facing communication. FinCEN created this cover page with the consumer in mind so the language is straight forward and digestible. Select verbiage can be used to draft your website banner, statement stuffers, social media posts or scripts for frontline staff. You can also provide it in its entirety to customers when the certification is provided.

  1. Lobby Signage

Do not underrate the power of signage in your office. Again, this is something that you can collaborate with your marketing team on. Much like the website banner, provide a clear, concise message to inform your customers of the new regulation. Simply providing a sign for the font door or poster board near the teller desk will add color to your lobby and increase your customers’ awareness of the changes they can expect come May.


By following these steps, you will be informing your customers of the INDUSTRY wide change, rather than an INSTITUTION policy change. Your front line will appreciate the initiative you have taken.

And, if you are still feeling unprepared for the regulation, Banker’s Toolbox can help! We are committed to making sure you are 100% compliant by May 11th. Check out our Due Diligence Manager solution, Beneficial Ownership Readiness Plan and other Beneficial Ownership resources.


Chris Benoit, has worked at Banker’s Toolbox for 5 years as a Sales Engineer and Project Manager. Chris has over 15 years of working in the Banking and Finance Industry. He started his career as a Branch Manager before moving into the Compliance Department as an internal auditor, where he oversaw BSA/AML and compliance for the Central Texas and Southern California. Chris is a graduate of Lamar University in Beaumont, TX. Chris’s areas of expertise are CDD/EDD/Beneficial Ownership, BSA Program Evaluations, Case Management and SAR Creation, and BSA Automation Technical Specifications. Chris holds a great passion for mitigating financial crimes and is working towards his CAMS certification. 


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