Important Information About Beneficial Ownership Rules

What is Beneficial Ownership?

To help the government fight financial crime, Federal regulation requires certain financial institutions to obtain, verify, and record information about the beneficial owners of legal entity customers. Legal entities can be abused to disguise involvement in terrorist financing, money laundering, tax evasion, corruption, fraud, and other financial crimes. Requiring the disclosure of key individuals who own or control a legal entity (i.e., the beneficial owners) helps law enforcement investigate and prosecute these crimes.

A legal entity includes a corporation, limited liability company, or other entity that is created by a filing of a public documents with a Secretary of State or similar office, a general partnership, and any similar business entity formed in the United States or foreign country.

A legal entity does not include sole proprietorships, unincorporated associations, or natural persons opening accounts on their own behalf.

What information do I have to provide?

Each time an account is opened for a covered legal entity, you are required to provide the name, address, date of birth and Social Security number (or passport number or other similar information, in the case of Non-U.S. Persons) for the following individuals (i.e., the beneficial owners): 

• 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); and
• 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).

The Bank will also ask to see a copy of a driver’s license or other identifying document for each beneficial owner and manager listed for the legal entity.

What is a Beneficial Ownership Certification form and why do I need to complete it?

The Beneficial Ownership Certification form is a legally required form that banks must collect from legal entity customers regarding their beneficial owners and the control person. When you complete this form, you are attesting that the information provided is accurate.

Do I need to provide personal information for people who are beneficial owners or control persons but not customers of the Bank?

Yes, information about beneficial owners and control persons must be provided even if they are not customers of the Bank.

How will the change impact existing accounts?

There will be no impact to your existing accounts. This information is requested only when you open a new account or request changes to an existing account.

Questions?

If you have any questions regarding this regulation or change in procedure, please contact your local branch by clicking here.