WASHINGTON — The Defense Credit Union Council is supporting a final rule from the Treasury Department’s Financial Crimes Enforcement Network that permanently removes beneficial ownership reporting requirements for U.S. companies and U.S. persons under the Corporate Transparency Act, while America’s Credit Unions has also released its analysis.
DCUC said the FinCEN action provides regulatory relief while allowing the government and financial institutions to focus resources on genuine financial-crime and national-security threats.
“This final rule is an important recognition that America’s financial institutions, small businesses, and military-connected communities need regulatory frameworks that are both effective and practical,” DCUC President and CEO Anthony Hernandez said in a statement.
Hernandez, a retired U.S. Air Force colonel, said DCUC will continue advocating for policies that protect national security and the financial system while allowing credit unions to devote resources to serving members, military personnel and their families.
‘Common Sense Relief’
DCUC Chief Advocacy Officer Jason Stverak called the rule “common-sense regulatory relief,” arguing that additional reporting requirements do not necessarily improve financial security.
“America can aggressively combat money laundering, fraud, terrorist financing, and other illicit activity without forcing millions of law-abiding small businesses to continually prove to the federal government that they are not criminals,” Stverak said.
Stverak said credit unions experience the cumulative costs of regulatory requirements through additional technology, compliance resources, employee time and other expenses. Those costs can be particularly significant for smaller credit unions and the small businesses, military entrepreneurs, veterans and military families they serve, he said.
DCUC said it has advocated for a modern, risk-based Bank Secrecy Act and anti-money laundering framework that concentrates government and financial institution resources on areas posing genuine threats.
“We should judge our financial-crime framework by whether it stops criminals and protects national security, not by the number of forms filed, databases created, or records collected,” Stverak said.
Getting ‘Smarter’
He added that as Treasury implements the rule and determines how to handle previously submitted beneficial ownership information, legitimate law enforcement and national security needs should remain protected.
“Effective regulation is not synonymous with more regulation,” Stverak said. “The objective should be smarter regulation, and today’s action moves us closer to that goal.”
America’s CUs’ Analsysis
In its analysis, America’s Credit Unions said, “While the direct impact on credit unions is limited, as credit unions are not considered small businesses in the text of the Corporate Transparency Act,” its Compliance Team examined the impact of the pause in BOI requirements announced in March 2025.
America’s Credit Unions said the final rule adopts the exemptions set out in the March interim final rule, making the rollback of beneficial ownership reporting by U.S. companies permanent and also:
- Permanently exempts U.S. persons who have obtained FinCEN IDs from any obligation to update or correct the information they originally provided to FinCEN to obtain their FinCEN IDs;
- Eliminates the requirement for foreign companies to report U.S. person “company applicants” (i.e., the individuals who helped those foreign companies register to do business in the United States);
- Exempts foreign pooled investment vehicles registered in the United States from reporting the beneficial ownership information of a U.S person in control of the investment vehicle; and
- Confirms that FinCEN will delete information about any individuals—company applicants, beneficial owners, or recipients of a FinCEN ID—that FinCEN reasonably believes is a U.S. person (e.g., the information is linked to a U.S. passport or U.S. driver’s license).
