Rep of coop certifies there are no 25% ben. owners. You, knowing the nature of the coop, have no reason to doubt the statement. You have the control individual's name, and you verify her identity using whatever method you've adopted. That takes care of the B.O. rule. Of course, if you don't already have an account open for the coop, you'll run the coop thru your CIP, too.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8