We are planning to implement the beneficial ownership rule as of May 1st. I conducted training today for our loan documentation department and was advised that there are documents out for signatures that will likely be returned after our launch date.

If we implement early and in between May 1st and May 11th there are some loans that don't have the CBO form, I'm thinking that we are fine as the effective date is not until May 11th.

For those of you that implemented early, how did you handle this?

We began Beneficial Ownership on 04/02/2018, the first business day in April. Any loans that had been started prior to April 2, 2018 were not subject to the B.O. requirements, although the lending officers could obtain it if they so desired.

So for example, loans that were started in March and had a March date on the loan application, or another similar document, etc. would not apply for Beneficial Ownership. These loans would likely be put on the system in April and have an April system date, but we would have documentation that the loan process actually started in March, before we implemented Beneficial Ownership.

We started April 16th and I gave leeway to any accout that opened before May 1, at the officers discretion, BO 0would not be required. After that all accounts, all the time.

banker1976,

Ok. I get what you both are saying and that worked for you because you implemented early. I'm not so sure that approach works form me as I'm running up against the mandatory effective date. If a loan is in pending status, and will not be disbursed until after May 11, 2018, then there was an opportunity to obtain the form.

The form must be obtained for any new account that is opened by a legal entity customer on or after May 11, 2018.

Now that I'm thinking this through, I believe my only alternative is to make the form available today on our Intranet and advise our RMs to obtain the form for any loan that they expect to fund on or after May 11, 2018.

Under Question 1 on the definition of "account" in the FAQ on CIP requirements, we read, "when the account is a loan, the account is opened when the bank enters into an enforceable agreement to provide a loan to the customer."

John,

Thank you for that reminder! We won't draw docs without it, so we will be fine.

Not sure about those folks using LaserPro........ I agree that the form needs to be provided at the time of application. Not at closing.