By Carlton Greene and Danielle Giffuni (October 31, 2018, 1:30 PM EDT) -- On Sept. 28, 2018, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corp., the National Credit Union Administration, and the Office of the Comptroller of the Currency (collectively, the federal banking agencies, or FBAs), with the concurrence of the U.S. Department of the Treasury's Financial Crimes Enforcement Network, issued an interagency order exempting premium finance accounts from the requirements of the customer identification program rules imposed by the Bank Secrecy Act. The exemption applies to banks and their subsidiaries subject to the FBAs' jurisdiction that offer loans to commercial customers (i.e., corporations, partnerships, sole proprietorships and trusts) to facilitate purchases of property and casualty insurance policies (herein referred to as premium finance loans or premium finance lending). The FBAs based their exemption on FinCEN's conclusion that certain structural aspects of such loans make them a low risk for money laundering or terrorist financing, and also on their own conclusion that such lending did not present a safety or soundness issue....