We've just started implementing BO and are hitting a roadblock in listing ultimate beneficial owners. (ABC Company is getting a loan; ABC Company is owned 100% by XYZ Company; XYZ Company is owned 50% by Jim and 50% by Bob. LaserPro won't let us list Jim and Bob as beneficial owners of ABC Company.) LaserPro is our loan platform. We've contacted LaserPro but have not heard back from them yet. I'm not sure if we are still just working out kinks in a new process, or if the software is unable to handle multiple levels of ownership.

Also, in the situation listed above, I assume we obtain and keep two separate certifications for the two companies for the one loan.

Thoughts?

FinCen just issued FAQ's on Tuesday. You should escalate immediately to someone else at LaserPro.

[url=ttps://www.fincen.gov/sites/default/files/2018-04/FinCEN_Guidance_CDD_FAQ_FINAL_508_2.pdf][url=ttps://www.fincen.gov/sites/default/files/2018-04/FinCEN_Guidance_CDD_FAQ_FINAL_508_2.pdf][url=ttps://www.fincen.gov/sites/default/files/2018-04/FinCEN_Guidance_CDD_FAQ_FINAL_508_2.pdf]ttps://www.fincen.gov/sites/default/files/2018-04/FinCEN_Guidance_CDD_FAQ_FINAL_508_2.pdf[/url][/url][/url]

You could do the certification form by hand if you are in a pinch.

There is no pre determined method for documenting ownership at the subterranean levels. One way would be to get an Appendix A for the customer and another for each legal entity purported to own 25% or more. While I would assume any vendor would have a proposed work around, Daisy's should allow you to proceed...

The rule requires you to get a certification from your borrowing entity that Jim and Bob each own 50% beneficial interest in the borrowing entity. You don't need anything from or about XYZ for this purpose. Of course, the certification will have to identify a control-prom individual, too.

Don't depend on your system for this rule until it gets updated to conform to the rule and FinCEN's interpretations of it.