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Recent changes to federal banking regulations require all U.S. financial institutions to collect information regarding the beneficial ownership of our legal entity customers. At account opening, and at times during the life of the account, the bank will ask you to provide identifying information for all natural persons who, directly or indirectly, own 25 percent or more of the equity interests in the legal entity. In certain situations, we may ask for identifying information below 25 percent. We will also request identifying information for a controlling person, such as an executive officer or senior manager, or another individual who regularly performs similar functions.
These changes take effect May 11, 2018.
Where do I start? What’s the easiest way to prepare?
We understand this may be disruptive. Our desire is to have our clients be as prepared as possible at new account opening to avoid any delays. To assist with this, we have created a paper form that your team can use to collect the required information prior to coming into the branch.
Beneficial Ownership Certification 25 - Form required for individuals who own 25% or more of the equity interests of the entity is used for non-High Risk entities.
Beneficial Ownership Certification 20 - Form required for High Risk Entities and individuals who own 20% or more of the equity interests of the entity.
For more information about Beneficial Ownership, we encourage you to read through the Beneficial Ownership FAQs.