In the exemptions from the rule, they list "political subdivisions of any state". Are election accounts considered to be a political subdivision? By election accounts, I am refering to your local democrat/republican office that opens a campaign account for Joe Smith who is running for mayor/governor/judge ; and accounts opened by Joe Smith to fund his campaign. I don't think this is what the rule is meaning to exempt here, but the question was brought up so I am researching this and can't find anything that specifically defines that in the rule.

These entities are excluded because they are subject to Federal or State regulation and information regarding their beneficial ownership and management is available from the relevant Federal or State agencies.

A person described in § 1020.315(b)(2) through (5) of this chapter— § 1010.230(e)(2)(ii)

This includes the following:

- Any entity established under the laws of the United States, of any State, or of any political subdivision of any State, or under an interstate compact between two or more States, that exercises governmental authority on behalf of the United States or of any such State or political subdivision. This category is also appropriate for exclusion due to the amount of ownership and management information that is publicly available about such entities.

Does the organization have the authority to tax? (e.g. Park District, Public School District, Water Reclamation District, etc.) If yes, it is excluded from the definition of a legal entity. If no, then it is covered by the rule.

Do you know where that is defined in the rule/other location? I hate telling departments "because I said so" without a source.

An election account - does not "exercises governmental authority "

"Exemptions" and "exclusions" are two different things under this regulation; the words are not synonyms.

For this "exclusion" to apply you would have to be talking about a legal entity customer established by a government entity; e.g. a corporation or an LLC established by federal, state, or local government. That happens, but it is incredibly rare.

The account's purpose, campaign funding, is irrelevant. Start with whether the account is opened by a legal entity customer. If not, there's nothing to talk about.

Just had a question concerning this today. It's an election account. Told the new accounts rep to obtain Control Prong. Not sure this is correct, but it's not May 11th yet!

The establishment of an election account does require a filing with the SOS, but I'm not exactly sure what TYPE of entity they are. Does anyone know?

I'd check their filing with the secretary of state/similar office in your state. That should tell you what type of entity they are, and from there you should be able to determine if it meets the definition of a LEC.

Insurance companies regulated by the state are exempt. How should we view insurance agencies/brokerages?

State Farm Insurance - exempt
John Doe Insurance Agency - exempt or not exempt?

Agents for insurance companies are not exempt. You'd need to have the customer indicate if there are any beneficial owners that have equity interests greater than 25% and list a control person. This was discussed in a separate thread a while back.

I see the idea of "authority to tax" and "exercise government authority" - would the city's public library be excluded?

Thanks!

If it actually part of the City government - yes.

Would a DBA account fall into the exemptions for Beneficial Ownership and only need CIP to be collected?

Define a DBA account? You mean a sole proprietorship? If so, then the account would be exempt.