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#2172426 - 04/06/18 09:00 PM Question 10
ahkcompliance Offline
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Midwest
Question 10 is about certification when a entity opens multiple accounts.

The answer that if a institution has already obtain a Certification form for the beneficial owners of the legal entity customer then it may rely on that information to fulfill the beneficial ownership requirement for subsequent accounts provided the customer certifies or confirms that the information is up to date.

This is on confusing me. Maybe its because its Friday at 4 pm. So if they open an account today and then open another account in a month that we can just have the confirm the Certification form is up to date?

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#2172436 - 04/06/18 09:30 PM Re: Question 10 ahkcompliance
Elwood P. Dowd Offline
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certifies or confirms (verbally or in writing)

and you keep a record of it for five years after the account is closed.
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#2172437 - 04/06/18 09:38 PM Re: Question 10 ahkcompliance
ahkcompliance Offline
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Instead of filling out the certification form again, can the person just sign a statement certifying everything is correct?

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#2172537 - 04/09/18 04:15 PM Re: Question 10 ahkcompliance
P*Q Offline

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If a customer is opening multiple accounts in one sitting, one form only or a form for each account (assuming the owners are all the same)?

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#2172591 - 04/09/18 06:50 PM Re: Question 10 ahkcompliance
Cape Codder Offline
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If multiple accounts are opened in one sitting, we're obtaining one certification with all account numbers listed.
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#2172592 - 04/09/18 06:54 PM Re: Question 10 ahkcompliance
ahkcompliance Offline
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Does the FAQ pertain to only accounts opened the same day or future ones as well?

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#2172593 - 04/09/18 07:04 PM Re: Question 10 ahkcompliance
Daisy Doodle Offline
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We are using a vendor form embedded in our deposit account boarding system. It does not allow (currently) for multiple account numbers to be inputted. We could print the form, manually add the other account number(s), then manually scan it back in, but I think we are leaning toward just producing one form per account and getting them all signed. No printing, no scanning that way.

The vendor told me they are working on multiple suggestions from banks to make the form better. I think we will see improvements in this process in time.

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#2172604 - 04/09/18 07:34 PM Re: Question 10 ahkcompliance
Compliance Lover Offline
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So if you are "verbally" confirming the beneficial ownership info hasn't changed from when the last account was opened, should you verify with the person who signed/certified on the last form?

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#2172611 - 04/09/18 08:04 PM Re: Question 10 ahkcompliance
TryingtoComply Offline
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Seems to me that if you are verbally verifying that you should keep a record of WHO you verified the information with.
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#2172635 - 04/09/18 08:37 PM Re: Question 10 ahkcompliance
HMS Pippii Offline
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Daisy Doodle - which vendor? PM if you don't want to put it here.
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#2172643 - 04/09/18 09:49 PM Re: Question 10 Cape Codder
Buddy the Elf Offline
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Originally Posted By Cape Codder
If multiple accounts are opened in one sitting, we're obtaining one certification with all account numbers listed.


Same for us. We ran it by our legal counsel and they were okay with doing it.
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#2172647 - 04/09/18 10:56 PM Re: Question 10 ahkcompliance
#Just Jay Offline
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Each account will have its own cert in our shop... this mitigates the possibility of the cert not following the along to and with the final account that eventually closes.

The burden will be minimal, and our confidence of compliance high.
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#2172788 - 04/10/18 05:43 PM Re: Question 10 ahkcompliance
ahkcompliance Offline
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The more I think about it, I think the original form would most likely follow the original account and get lost somewhere and not meet the 5 year period. I think we will go with new form for each account except for CD renewals as long as the same account number.

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#2172843 - 04/10/18 07:32 PM Re: Question 10 ahkcompliance
TryingtoComply Offline
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Doing the same (one form for each account). If multiple accounts are opened simultaneously, we are instructing staff to have the customer complete ONE CBO which will be photocopied for each account opened. We have sections at the top to record bank use information that includes the account number.
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#2172856 - 04/10/18 07:54 PM Re: Question 10 ahkcompliance
ahkcompliance Offline
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Midwest
Regarding form...are you using a vendor form or your own? As of now we are using vendor but we may go with our own. Our business team wants to use a word form so they can fill out and save for each business. Then if they open a new account, all they need to do is retrieve the form and have the person opening the account review and sign.

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