October 28, 2002

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InfoBytes Special Alert

Consumer Finance Headlines & Deadlines of Interest to our Clients and Friends

Treasury Postpones Effective Date of USA PATRIOT Anti-Money

Laundering Program Requirement For Certain Types of Financial Institutions

On October 25, the Financial Crimes Enforcement Network of the Treasury

Department (FinCEN) indefinitely postponed the effective date of Section 352 of
the USA PATRIOT Act (which requires all financial institutions covered by the
Bank Secrecy Act to institute an anti-money laundering program) for certain
financial institutions including loan and finance companies.

In rules published in April, implementing the anti-money laundering program

requirement for banks, securities broker/dealers and certain other financial
institutions, FinCEN deferred the effective date of Section 352 for other financial
institutions until October 26. The October 25 release extends the deferral until
rules specifically require these other categories of financial institution to implement
an anti-money laundering program. This deferral applies to all of the following
financial institutions: dealers in precious stones, metals or jewels; pawnbrokers;
loan or finance companies; private bankers; insurance companies; travel agencies;
telegraph companies; sellers of vehicles, including automobiles, airplanes and
boats; persons engaged in real estate closings and settlements; investment
companies other than open-end mutual funds; commodity pool operators; and
commodity trading advisors.

FinCEN's release notes that it intends to propose rules on anti-money laundering

programs for all of these other financial institutions within six months. The release
notes that proposed rules for financial institution including insurance companies
and investment companies have already been published. It does not state whether
final rules for insurance companies and investment companies will be issued before
new proposed rules are issued for the other categories of financial institutions.
The release is available at http://www.ustreas.gov/press/releases/po3580.htm. If
you have any additional questions, please contact Jacob Thiessen at
jthiessen@goodwinprocter.com.

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Goodwin Procter LLP (http://www.goodwinprocter.com ) Consumer Financial Services Practice

In Washington Jeremiah S. Buckley Joseph M. Kolar Jeffrey P. Naimon

Andrea Lee Negroni John P. Kromer R. David Whitaker
Margo H. K. Tank Melissa L. Barrett Jonathan D. Jerison
P. Nick Koufos Patricia S. Mugavero Christopher M. Witeck
Jacob G. Thiessen Vincent D. Schaper Michael P. Whalen
Nikita Pastor Lorna Neill Victoria Crane
Carla Abel Kimberly Smith Jennifer Beall
Teresa Lozeau
Thomas M. Hefferon (Litigation) David L. Permut (Litigation) Ellen Quattrucci (Litigation)
Camilla Jackson Jones (Litigation) John Ekman (Litigation) Scott Nardi (Litigation)
Andrew Louis (Litigation) Sally Pullman (Litigation)

In Boston Lynne B. Barr John C. Englander (Litigation) F. Dennis Saylor (Litigation)

Christine McManus Brooks R. Brown (Litigation) Sarah E. Walters (Litigation)
Margaret B. Crockett F. Beirne Lovely Jr. (M&A) James W. McGarry (Litigation)

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The information in InfoBytes is gathered from news and other sources and is intended for informational purposes only; it
should not be construed as legal advice to any person. Goodwin Procter assumes no liability for any person’s reliance on
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Massachusetts. ©Goodwin Procter LLP 2002