What's the Dilly-o with business account opening: a buyer's guide for credit unions
On February 13, 2026, FinCEN freed covered institutions from identifying and verifying a business's beneficial owners at every new account opening.1 On August 11, 2026, FinCEN also finalized a rule that exempts U.S. companies from filing beneficial ownership reports with it.23
The Dilly-o
If you rely on ownership information you already hold, you must keep a record of each certification or confirmation, verbal or written.4 We'd ask any platform to show you where it would store that record.
How we'd size up a vendor
- Business verification - every platform in this category must verify the business, so ask how it does that.C Ask to see a refer or decline on a real test case, not only a clean approval.
- Ownership records - if you rely on ownership information you already hold, you must keep a record of each confirmation, verbal ones included.4 Ask to see where the platform stores that record.
- Document fraud - FinCEN has warned that criminals use identity documents made with generative AI to open funnel accounts.5 Ask the vendor what it flags and what it sends to your staff for review.
- Core fit - does the vendor have a working connection to your core today, and who maintains it? A listed connection is a starting point, so ask for a credit union already live on your core.
What changed this year
To rely on information you already hold, the business must confirm, verbally or in writing, that it is up to date and accurate.4 You must also know of nothing that calls it into question.4 Keep a record of that confirmation, verbal ones included.67 FinCEN's August 2026 final rule makes the beneficial ownership reporting exemption permanent for domestic companies.89 It took effect on August 14.89 On the payments side, Nacha's 2026 rules count payments induced by lying about identity, authority to act for another, or account ownership as fraud.10 We'd take that as a reason to look hard at how your platform checks a business and the people acting for it.
Will it work with your systems?
Platforms in this category must offer a digital application and business verification.C As of November 9, 2026, Clutch appears in the Jack Henry Fintech Integration Network listing for Symitar credit unions, under Lending and Deposits.C We haven't reviewed Prelim's core fit yet.C Whichever you look at, ask your provider which cores and digital banking platforms it runs on in production today, and name the credit unions using that setup.
What other credit unions did
America First Credit Union built digital business account opening with Loquat, and announced early results on November 21, 2025.11 The credit union says owners can apply online, in its mobile app or at any of its 116 branches across six states.11 It also says some applicants finished the whole process in as little as five minutes.11 We'd ask any vendor for a peer reference like that, with numbers from the credit union and not from the vendor.
What your examiner will ask
Your Bank Secrecy Act (BSA) program must include internal controls, independent testing, a designated compliance officer and training.12 For business accounts, the control prong names one individual with significant responsibility to control, manage or direct the business.13 NCUA expects vendor contracts to cover service levels, records access, audit rights, data security, business resumption and termination terms.14 It also points to review by qualified external legal counsel.15 We'd keep your owner confirmation records, the vendor contract and your due diligence file in one place, so you can show them on request.
What it costs
Neither vendor in this category publishes pricing, so plan to ask for a three-year total cost in writing. One account opening playbook puts digital account opening at 12 to 16 weeks from contract signing to launch.16 NCUA notes that some credit unions signed agreements with significant buyout or termination penalties, believing those terms could not be negotiated.17 It says early termination, escape clause and default terms are often negotiable.17 Missing termination terms, weak data access rights and unclear audit terms are common gaps in these contracts.18 Negotiate the drawbridge before you sign, so you can get your data out if you leave.
Food for thought
U.S. companies no longer file beneficial ownership reports with FinCEN.2 We'd settle that policy before you pick a vendor, because it shapes what the platform has to do.
Dilly Labs research, written from our catalog and cited sources · updated . Credit unions pay nothing. Vendors pay a referral fee only when a contract is signed through us. It never changes rankings or this guide. How we work
Sources
- CDD Rule FAQswww.fincen.gov
Whether a covered financial institution chooses to avail itself of the Account Opening Exceptive Relief Order is within the discretion of the covered ...
- Beneficial Ownership Information Reportingwww.fincen.gov
Under the final rule: - **U.S. companies are exempt** from BOI reporting requirements and therefore, are no longer required to file BOI reports.
- Beneficial Ownership Information Reportingwww.fincen.gov
The final rule became effective on August 14, 2026.
- CDD Rule FAQswww.fincen.gov
When scenario (3) arises—that is, when a covered financial institution determines, based on its risk-based procedures for conducting ongoing customer ...
- FinCEN Warns Financial Institutions of Fraud Schemes Arising from Deepfake Media Using Generative Artificial Intelligencewww.jdsupra.com
FinCEN is aware of situations where accounts have been successfully opened using such fraudulent identities and have been used to receive and launder ...
- FinCEN Eases Beneficial Ownership Verification Requirements: What Financial Institutions Need to Knowwww.mintz.com
For the third scenario, financial institutions may rely on previously submitted beneficial ownership information so long as the customer certifies or ...
- FinCEN streamlines CDD requirements, reducing compliance burden for covered financial institutionswww.davispolk.com
[5] FinCEN also states that covered financial institutions must maintain a record of any beneficial ownership certification or confirmation, including...
- FinCEN Ends Beneficial Ownership Reporting Requirements for U.S. Companieswww.mofo.com
The rule permanently exempts domestic reporting companies from beneficial ownership information (BOI) reporting under the Corporate Transparency Act (...
- FinCEN Ends Beneficial Ownership Reporting Requirements for U.S. Companieswww.mofo.com
The final rule adopts with limited changes the interim final rule issued in March 2025.
- ACH Fraud Rules Are Shifting: What Nacha 2026 Means for Banks and Credit Unions - ThreatMarkwww.threatmark.com
Nacha defines “false pretenses” as the inducement of payment by a person by misrepresenting (a) that person’s identity, (b) that person’s association ...
- America First Credit Union's Digital Business Account Opening Sees Strong Early Adoptionwww.prnewswire.com
Some applicants have completed the entire process in as little as five minutes.
- 12 CFR § 748.2 - Procedures for monitoring Bank Secrecy Act (BSA) compliance.www.law.cornell.edu
Such compliance program shall at a minimum— (1) Provide for a system of internal controls to assure ongoing compliance; (2) Provide for independent ...
- FFIEC BSA/AML Assessing Compliance with BSA Regulatory Requirements - Beneficial Ownership Requirements for Legal Entity Customersbsaaml.ffiec.gov
Under the control prong, the beneficial owner is a single individual with significant responsibility to control, manage or direct a legal entity custo...
- Evaluating Third Party Relationshipsncua.gov
- Typically, at a minimum, third party contracts should address the following: - Scope of arrangement, services offered, and activities authorized; - ...
- Evaluating Third Party Relationshipsncua.gov
It is prudent to seek qualified external legal counsel to review prospective third party arrangements and contracts.
- Digital Account Opening Playbook (2026)creditunionwebsolutions.com
Implementing a new credit union online account opening platform typically takes 12 to 16 weeks from contract signing to launch.
- Evaluating Third Party Relationshipsncua.gov
For example, some credit unions have entered into third party agreements with significant buyout or termination penalties, believing the penalties or ...
- NCUA Third-Party Guidance for Collateral Technology: What Credit Unions Need - Aaim Institutionalwww.aaim.com
Contract gaps appear frequently: missing termination provisions, inadequate data access rights, unclear audit provisions.