May 2018
Premium Finance Cash Refunds and Beneficial Ownership Requirements for Legal Entity Customers
The Financial Crimes Enforcement Network (FinCEN) is issuing this ruling to provide exceptive relief to covered financial institutions with respect to the application of the Beneficial Ownership Requirements for Legal Entity Customers (31 CFR § 1010.230) (Beneficial Ownership Rule) to premium finance lending products that allow for cash refunds. Premium finance lenders provide loans to businesses to cover insurance premiums. In the normal course of business, premium finance lenders process a significant number of cash refunds each year.