Okay, so I know there are a few threads out there covering IOLTA's and Beneficial Ownership. Having said that, we have a non-profit customer that consists of many different law groups and it is confusing me with respect to collecting BO information. Here is the example:
1. Law Foundation is a non-profit with the board made up of attorneys from different law firms throughout the state
2. Law Foundation sends paperwork with Law Firm Customer A and they open account under the Law Foundation account as a subaccount. Firm Customer is not the primary.
Do we collect BO information on the Foundation and the Firm? I understand the FinCEN guidance on if the attorney opens up the account under themselves, but this is ran through an intermediary. Help appreciated!!!