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#2164841 - 02/15/18 10:41 PM Beneficial Ownership - % required?
Goodland Offline
Junior Member
Joined: Nov 2015
Posts: 35
I have read the regs and have not found anywhere that obtaining the % is required. Our lending folks use a document provided that insists they need the % on the form, yet the appendix A does not have % on the form.

Thoughts?

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BSA/AML/CIP/OFAC Forum
#2164846 - 02/15/18 10:49 PM Re: Beneficial Ownership - % required? Goodland
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
They may be using it for other purposes, such as figuring out who has to guarantee the loan.
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#2164851 - 02/15/18 11:25 PM Re: Beneficial Ownership - % required? Goodland
McFly Offline
Member
Joined: Nov 2016
Posts: 75
Nope - not required. However, it may be useful to have the percentages, and we plan to collect this information.
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#2164890 - 02/16/18 02:57 PM Re: Beneficial Ownership - % required? Goodland
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
Our form will not have them, but our core is being enhanced to collect.

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#2164897 - 02/16/18 03:23 PM Re: Beneficial Ownership - % required? Goodland
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Adding the percentage of ownership is a popular modification. Without it, you will have no idea whether an OFAC hit on Abril Cortez requires you to act; i.e. if he owns less than 50% it does not.
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#2164975 - 02/16/18 05:44 PM Re: Beneficial Ownership - % required? Goodland
Pat Patriot Act Offline
Gold Star
Pat Patriot Act
Joined: Apr 2009
Posts: 450
I've talked to a lot of BSA folks at different Institutions about this, and most are going to collect percentages. So in addition to everything else already mentioned, it may end up being an auditor/examiner expectation right out of the gate.
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