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#2150504 - 10/19/17 04:06 PM CDD/BO and Participations and Syndications
downbytheriver Offline
Member
Joined: Jan 2008
Posts: 51
Georgia
Can anyone tell me if we are required to obtain the beneficial ownership certification for participations (not the lead bank) and syndications? We currently rely on the lead bank to obtain this information for CIP. Not sure what is required for these entities under the new CDD/BO.

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#2150562 - 10/19/17 08:32 PM Re: CDD/BO and Participations and Syndications downbytheriver
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
If a loan is to a legal entity customer and your bank is required to perform CIP, then you are required to obtain the beneficial ownership information. If your bank is not required to perform CIP, then it is not required to elicit the beneficial ownership information.

Generally, in a participation loan you are not opening an account so neither requirement would be applicable.

Not reflected in that analysis is the fact that you should want the information as a part of your underwriting process.
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