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?

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.

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.