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#2177293 - 05/08/18 10:58 PM BO Certification
Goodland Offline
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Joined: Nov 2015
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Does the address on the Beneficial Ownership Certification need to be a physical address for the BO's and Responsible Manager?

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#2177295 - 05/08/18 11:27 PM Re: BO Certification Goodland
GuitarDude Offline
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So Cal
Yes, the requirement follows the CIP rules.
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#2177444 - 05/09/18 06:29 PM Re: BO Certification Goodland
ComplianceNewbie Offline
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FinCEN's Appendix A specifically says residential or business street address for both prongs.

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#2177468 - 05/09/18 07:04 PM Re: BO Certification Goodland
John Burnett Offline
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And the FAQs explain that the same rules for those addresses apply as for CIP. It can be an APO or FPO address or a street address for a family member or other contact person. Frankly, I think most banks will restrict those limits a bit more to the street address of the individual or the business.
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#2177471 - 05/09/18 07:10 PM Re: BO Certification Goodland
Adam Witmer Offline
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For reference, here is the FAQ that John mentioned:

Q What address should be obtained for a legal entity customer’s beneficial owner(s) to comply with the certification requirement – residential or business?

A. The address requirements for certification under the CDD Rule are the same as those outlined in the CIP rule. For an individual beneficial owner, covered financial institutions must obtain either a residential or a business street address. If neither is available, acceptable substitutes may include an Army Post Office (APO) or Fleet Post Office (FPO) box number, or the residential or business street address of next of kin or of another contact individual.
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All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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#2177481 - 05/09/18 07:24 PM Re: BO Certification Goodland
John Burnett Offline
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Thanks, Adam. And for the record, the bit about most banks trimming back those options is strictly my opinion based on what I believe they have done with CIP. And it's also not very likely you will have a beneficial owner with an APO or FPO address.
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#2177488 - 05/09/18 07:29 PM Re: BO Certification John Burnett
Adam Witmer Offline
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Originally Posted By John Burnett
And for the record, the bit about most banks trimming back those options is strictly my opinion based on what I believe they have done with CIP. And it's also not very likely you will have a beneficial owner with an APO or FPO address.
I agree that most community banks will mainly see a street address unless they happen to have a branch close to a military base. I view the FAQ as more of an available option (exception to the norm) when needed.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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