Please provide feedback on what other Banks are doing ---

1. When during the processing of a loan application is the beneficial ownership certification form being required to be completed and submitted to the bank?

2. Is the beneficial ownership information embedded in your application form?

3. For C&I and CRE loans that you do not have an application form, when/at what point is the beneficial ownership certification form required to be completed and returned to the bank? How and by what manner are you sending the form to the customer to complete?

Thank you for your assistance with my questions.

We are planning to schedule a sub-group meeting to our BO project group to address this question, but Compliance (me+) wants to use our core CIS and embedded form it contains. This may change the timing of when the CIS record gets established for a loan. We'll see what the loan group says. I was told the loan origination software were adding the form.

If your bank requires personal guarantees from business owners, you will want to identify the owners early enough in the application process so you can evaluate their individual creditworthiness. If not, you're only looking for an information requirement that you are required to fulfill "at the time a new account is opened." I'll suggest that means any time prior to closing.

Thanks for the responses.

There is a separate credit investigation procedure that occurs on the beneficial owners. If they find negative news related to a beneficial owner (no party to the loan) they want the option of denying the loan.

Because of this procedure, I recommended the BO Cert be completed very early in the process, as in available when going into underwriting.

It makes sense to provide the form as soon as you have an "application." The earlier in the process the better, otherwise not having the form may delay closing. We will not fund a loan until the form is on file. We all know how hard it is to get a borrower to do something AFTER they have closed.