We are in our soft launch period for beneficial ownership and here's what we are experiencing already:

One customer was confused by the form (I used the model with some modifications). At the very top it states, "Persons opening an account on behalf of......" Our new accounts rep explained that only one person's name needed to be entered. I will be revising the form to eliminate the "s".

One call asking if a minor should be reported as a beneficial owner. I said "yes" if they actually were a beneficial owner. I'm trying to find out more about this.

One loan officer reported that "no one is a beneficial as his customer owns 100% of the entity!" I banged my head against the wall on this one.

Some confusion regarding non-profits. I'm having to remind them that they are not excluded from the Rule, just the Beneficial Owner Prong.

Would love to hear what others are experiencing!

Lol. Our soft launch was this week also. It's been nuts for me, IT, Deposit Ops, and Training! Many tweaks to our training materials and 'clarification emails' have gone out!

Yes, it has been crazy! Lots of clarification emails as well. It's so hard to think of everything when rolling out something BIG like this. I am exhausted and glad that it's Friday.....although I will be working on procedures all weekend!

I'm working this weekend also, but to catch up on cases and SARS.

You should have banged the loan officer's head against the wall.

I agree with John.

I was reviewing an account and got a BO form for a sole prop dba.

I thought I was pretty clear in training and the form instructions, but I guess not.

I hope they at least got the ownership right on the sole prop account!

On loans, are your officers collecting the information up front and having the lead person for the entity complete the form or are you allowing this to happen at loan closing. I have an officer who insists that he will get it at closing and not before because he doesn't see all the owners until that time. I would like the LO to provide he BO certification document up front when discussing the loan request and have it completed so that the loan processor has it when preparing the loan documents but I'm getting push back.

Our Loan Ops will not release the loan docs for closing without receiving a completed but unsigned BO Cert form. Seems very risky for a violation to wait until the closing table. Will he withhold the funding if they don't have all their info?

We launched April 2 and it's still crazy. Especially when FinCEN is giving out conflicting information to different banks.

I have had questions relative to loan modifications, loan participations, loan renewals, guidance lines, etc. Also my folks were confused between a BO "Requirements Guide" that is given to the customer to help them understand what they need to bring to the bank in order to open an account verses the actual Certification Form.

The latest that has me somewhat stumped is that some customers are asking officers of the Bank - well what type of stock constitutes beneficial ownership (i.e. voting vs non-voting stock). ANYONE GOT ANY INPUT ON THIS ONE?!?


Launches are always entertaining.

Yes - what John said !!

One of our lenders complained this morning--this is overkill getting ID for someone who is not a signer on an account. Is this REQUIRED??

HaHaHaHa....he must have slept through training!

He missed the point entirely!