IBAT issued a comment letter on FinCEN's proposal to develop a customer due diligence ("CDD") regulation. This new proposed CDD regulation is an attempt to bring "uniformity and consistency" in already established mandates such as "know your customer" and "customer identification program." It includes an expanded focus that also addresses two significant issues - customers acting as agents, and obtaining information on a beneficial owner. There is some serious doubt if the information that would be required would prove valuable in a bank's BSA/AML efforts or would assist in any legitimate law enforcement needs. IBAT feels the proposal is very problematic and will have serious unforeseen consequences for overly-burdened community banks.