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!