Hello All,

We have a situation where a for-profit company, which is a subsidiary of a non-profit company, wants to open a business account. I know for sure that the for-profit company falls under the BO rule and we will have to collect that BO information. However, I feel like we need to collect BO info on the non-profit (I guess a control person only since it is a non profit) since they own the for-profit company. Does that sound right??

Maybe I am over thinking this one. We just rolled out BO at my bank and already running into issues.

Thanks in advance!

You obtain the beneficial owners of your customer. The for-profit corporation is your customer. The holding company is not.