Comment on FR Doc # 2012-05187

Ref: RIN1506-AB15; Regarding Docket #FINCEN 2012-0001 FINCEN should take care not to make this CDD rule too broadbased or onorous as a FI's size, location and customer base should be taken into account. Our recommendation would be to only apply CDD rules if money is being disbursed to a beneficiary, rather than at account opening where the customer is merely listing beneficiaries. There are many account types whereby obtaining government issued identification, etc. is not feasible - IRAS (where the account owner often lists grandchildren as beneficiaries and contingent beneficiaries); IOLTA accounts where there is often attorney/client privilege, and IORETA accounts. In addition, this CDD rule should apply to new accounts opened after it is implemented, rather than retroactively as that would cause high compliance costs to financial institutions. It is feasible to obtain "basic" information regarding beneficiaries (with the exception of IOLTA/IORETA accounts), such as name, address, date of birth, and social security number as this will enable the FI to track down the beneficiary at some future point (in the case of death, etc.) but it should not be required to obtain idenfication from any beneficiary, unless funds are going to be shortly disbursed to that individual or entity.