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.

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.