Davis Polk partner Dan Stipano was quoted in American Banker on the Corporate Transparency Act and how it was intended to provide regulatory relief for banks from beneficial ownership information collection. Dan noted that “Congress's vision on this was to get banks out of the position of having to collect beneficial ownership information from all their legal-entity customers — perhaps they would do it on a risk basis, or just rely upon the registry.” He added that “it remains to be seen whether it will work out that way, because the implementing rules haven’t been issued yet.”

Beneficial ownership regulatory relief is far from assured,” American Banker (April 24, 2022) (subscription required)