We have some customers that are registered with our state as cooperatives. Where do those fall under the Beneficial Ownership rules?

Can anyone help me on this?

We have a utility cooperative as a customer. If I had to guess, I would say treat similar to pooled investment--get the control prong. If the owners are subject to frequent change, the concept would be similar.

But you could also email the FinCen Regulatory helpdesk, or ask your examiner's opinion. That would beat guessing.

I would not ask an examiner. Got straight to the source and ask FinCEN, as it's their regulation and document the response.