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As a result of the outreach referred to above, FinCEN obtained some additional data on which to better estimate the additional costs at account opening. Banks we surveyed estimated that it is likely to take an additional 10 to 15 minutes per beneficial owner. In its outreach FinCEN asked three small financial institutions the number of legal entity accounts they open each year. Although financial institutions don't usually keep information about the number and legal entities of their customers, they do maintain a database for individual customers (i.e. retail customers) and another database for customers who are businesses or organizations. A significant number of a financial institution's business or organization customers are sole proprietorships that are not legal entities subject to the proposed rule.
FinCEN supports the collection  beneficial ownership information in these other circumstances as well, it does not believe that such collection would replace the independent obligation of financial institutions to collect this information. This new requirement is based on the principle that financial institutions must know their customers to better manage risks. This requirement is therefore separate from a policy objective of requiring States to obtain beneficial ownership information from the legal entities they create at the time of formation and upon specified circumstances thereafter . Presently, corporate laws and regulations differ from State to State, and from FinCEN's regulations, but generally do not require information regarding beneficial ownership.
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Is routinely required for a variety of commercial interactions, such as obtaining an insurance policy, or verifying eligibility for employment in the United States via U.S. Accordingly, we reject the assertion of one commenter that it would not be possible. To convince some beneficial owners to provide their personal information" on the grounds that many people are "especially sensitive to disclosing personal information" .
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This measure is also supported by the CNIGA, which allows in-person betting at four racetracks and tribal casinos. Tribal groups could challenge Prop 27 in court based upon the Prop 26 five year ban on online sports betting. Last Sunday, the California Democratic Party made its position on two sports betting initiatives. The Democratic Party is against online betting but will remain neutral regarding retail betting.

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Given that the upper bound for costs used in the breakeven analysis is high, the breakeven analysis is therefore very conservative in specifying how effective the CDD rule would have to be in order to justify its costs. We believe this set of assumptions yields estimates that account for the primary factors that may affect costs in the period of analysis. Would fall sharply after the first year as the majority of first-year costs are due to time spent designing training modules for employees, a cost that we assume will  After the first year, the problem will not recur. We estimate that 10 year quantifiable costs will range from $1.15 to $2.15 trillion in present value using a seven percent discount rate, and $1.3 billion to $2.5 Billion using a three percent discount rate.
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