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Beneficial Ownership Requirements

What you need to know

Due to a change in federal banking regulations, we are required to obtain additional information during the account-opening process for business customers, as well as after other triggering changes to existing business accounts.

The goal of the new law is to help the government fight financial crime through enhanced identity verification practices. For us and you, our customer, it means we will require a Beneficial Ownership Certificate be completed with information about all beneficial owners and controlling interests before we can open a new account or establish a new service.

 

We have a new Beneficial Ownership Certificate that must be completed in order to open accounts for new business customers.

The regulation takes effect May 11, 2018. To ensure compliance, our new verification protocol will be in place beginning April 2, 2018.

We need information for the following individuals:

  • Beneficial Owner(s): Each individual, if any, who owns, directly or indirectly, 25 percent or more of the equity interests of the legal entity customer (e.g., each natural person that owns 25 percent or more of the shares of a corporation); could be as few as zero and as many as four individuals; and
  • Controlling Person(s): An individual with significant responsibility for managing the legal entity customer (e.g., a Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President, or Treasurer); at least one must be identified.

There can be up to four individuals (but as few as zero) identified as beneficial owners. Regardless of the number of beneficial owners, you must provide the identifying information of one controlling person. It is possible that in some circumstances the same individual might be identified under both sections (e.g., the President of Acme, Inc. who also holds a 30% equity interest).

The person opening a new account on behalf of a legal entity such as:

  • Corporation
  • Limited liability company or other entity that is created by a filing of a public document with a Secretary of State or similar office
  • General or limited partnership
  • Business trust created by a filing with a State Office
  • Any similar business entity formed in the United States or a foreign country
  • Charities and nonprofit organizations that have filed their organizational documents with the appropriate State authority (Controlling Person identification only)

For each beneficial owner and controlling person listed on this form, we will need:

  • Name
  • Address
  • Date of birth
  • Social Security Number (or passport number or other similar information, in the case of Non-U.S. Persons)
  • Copy of a driver's license or other identifying document

Legal entity does not include:

  • Sole proprietorships
  • Municipalities and government agencies or departments
  • Publicly traded companies
  • Trusts and estates
  • Unincorporated associations, such as youth or sporting groups
  • Natural persons opening accounts on their own behalf

Nonprofits are exempt from the ownership requirement, but we must still identify the controlling interest.

 

For more information, please speak to your Branch Manager.