Beneficial Ownership Rule
You and your business are important to us.
Effective May 11, 2018, all banks will be subject to new rules under the Bank Secrecy Act that will aid the government in the fight against crimes to evade financial measures to combat terrorism and other national security threats. This new rule requires covered financial institutions to identify and verify the identity of the beneficial owners of all legal entity customers.
Each time an account is opened for a covered Legal Entity, we will be required to ask for identifying information as well as documentation for each individual that has 25% or more Beneficial Ownership in the Legal Entity and one individual that has significant managerial control of the legal entity.
If you are opening an account on behalf of a Legal Entity, we suggest that you obtain the below information, for EACH identified individual. If your business will frequently be opening new accounts/loans, please keep this information current and available to present EACH time you come in to establish a new account.
- Full Name
- Home Address
- Social Security Number
- Date of Birth
- A copy of valid ID Document Number (Driver's License, State ID or Passport), which will include an issue date and expiration date
- Percentage of Ownership
While we understand the information requested is personal and sensitive, we need to obtain this information in order to comply with the law. As always, we will treat all information collected with the utmost care. All information will be stored securely and handled with the same standard of privacy that we have always maintained.
Covered Legal Entities include:
- LLCs (Limited Liability Companies)
- LPs (Limited Partnerships)
- General Partnerships
- Business Trusts
- Incorporated Charities*
- Non-excluded Pooled Investment Vehicles
*These entities are exempt from the Beneficial Ownership prong, but not from the control prong. The control prong is where we must identify a person who has significant managerial responsibility for the company.
Entities fully exempt from the rule include:
- Natural persons opening an account for personal use
- Sole Proprietors
- Unincorporated Associations
- Trusts not formed via State Filing
- Government Entities
- Companies registered with the Securities and Exchange Commission (SEC)
- Bank Holding Companies
If you have any questions, please do not hesitate to contact your Banker.