Here are Five Facts about FinCEN’s Final Rule. 1 financial institutions do not need to verify that the listed beneficial owners are the actual beneficial owners. 2 each financial institution can decide to collect beneficial ownership information for beyond the 25 percent required. 3 financial institutions do need to retain documentation when there is a change or update to beneficial ownership information. 4 a change in ownership should be considered a trigger event to review beneficial ownership information for existing accounts. and 5 financial institutions do not legally need to conduct annual reviews of their customers to maintain compliance. Watch our 0n-demand webinar to learn more about this important rule.