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#2170276 - 03/27/18 02:37 PM CDDBO on For Profit Cooperatives
moola741 Offline
Joined: Dec 2003
Posts: 86
We have many member owned for profit cooperatives that are legal entities, such as phone companies, grain elevators, farm supply stores etc as customers. I just want to make sure that we need the certification form completed by a qualified person from that business to note this fact that there are no 25% or more owners and do CIP on them. Correct?

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#2170427 - 03/27/18 06:54 PM Re: CDDBO on For Profit Cooperatives moola741
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,598
Cape Cod
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

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#2170519 - 03/28/18 12:29 PM Re: CDDBO on For Profit Cooperatives John Burnett
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Asked and answered, but this issue comes up over and over.

People ask: What about churches? What about labor unions? What about water districts? What about IOLTA's?

What about them?

The question is does the customer meet the definition of a "legal entity customer;" i.e. is it a creature of statute registered with the state; i.e. a corporation, LLC, etc. ? If it's not, well then the regulation only applies if it's a general partnership.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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