What is the expectation if one of our indirect automobile lenders sells a car to a Legal Entity customer, and we are providing the financing?? Appreciate any thoughts, guidance, and/or assistance!

The final rule allows you to rely on third parties to collect beneficial ownership information just as it allows you to rely on third parties to collect CIP information.

This should be addressed in your indirect loan contract with the dealer if you are relying on them to collect the beneficial owner information.

This Related Thread will provide additional information.

Thank you.

Is anyone willing to discuss how they are "training" their indirect auto dealers about collecting Beneficial Owner information, or how they plan to handle discrepancies?