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#2143985 - 08/29/17 03:18 PM Verifing Beneficial Owners?
Megaman Offline
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Joined: Jul 2017
Posts: 121
Am I reading the rule correctly???

The bank does not have to verify(Get copies of ID, ETC...) beneficial owners if it relies on the Beneficial ownership certification form (using the sample from FinCEN) as long as the bank has no knowledge of facts that would reasonably call into question the reliability of such information?

Basically having the person opening up the account complete the Certificate and we can rely on that for compliance?


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#2143997 - 08/29/17 03:39 PM Re: Verifing Beneficial Owners? Megaman
MScarn6942 Offline
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Joined: Aug 2015
Posts: 756
Land Lacking in Lakes, IL
It also states that you need to follow a process substantially similar to your current CIP procedures for verification
Last edited by MScarn6942; 08/29/17 03:46 PM. Reason: I can't type this morning
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#2144068 - 08/29/17 06:02 PM Re: Verifing Beneficial Owners? Megaman
BrianC Offline
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Joined: Nov 2004
Posts: 6,463
You do not have to verify that the beneficial owner is a beneficial owner (e.g. copies of stock certificates, organization docs) but you do have to verify enough information to form a reasonable belief that you have identified the person (as MScarn noted). The beneficial owner procedures may vary from your CIP verification. For example. the beneficial owner rule allows you to request a copy of a government issued ID instead of viewing the original since a beneficial owner may not be present at account opening. You do not have permissible purpose to obtain a credit or Chexsystems report on a beneficial owner so your non-documentary verification may need to change.
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#2150483 - 10/19/17 03:28 PM Re: Verifing Beneficial Owners? Megaman
downbytheriver Offline
Joined: Jan 2008
Posts: 51
So Brian are you saying that obtaining a copy of the government issued ID and obtaining the certification is sufficient for verifying the beneficial owner's identity (unless of course the documentation appears to be fraudulent, etc.)? We currently run IDV checks on authorized signers as well as OFAC but do not run the ChexSystems report you mentioned above. Since we are supposed to use similar verification to our bank's CIP would this require us to run the IDV for beneficial owner's as well? It would be a big time saver for the front line staff if the IDV piece was not required. I'm just not sure how everyone else is handling.

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#2150561 - 10/19/17 08:23 PM Re: Verifing Beneficial Owners? downbytheriver
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
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Next to Harvey
"IDV" translates to what, i.e. not the acronym, the process?
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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