Would some of you please share your wording regarding triggering events that you included in either your policy or procedures? I am leaning towards primarily only getting re-certification for things like new signers, ownership changes, CD renewals, loan renewals, and that's about it.

Bankwide procedures:
Triggering events to get new certification of beneficial ownership

1. Bank obtains knowledge of a change of ownership
2. Significant and unexplained change in the customer's activity (such as executing cross-border wire transfers for no apparent reason or a significant change in the volume of activity without explanation) that may indicate a possible change of ownership

Retail procedures added change in signers to inquire on change in owners.

Is a change of address or stop payment considered "triggering events?"

Stop payment? No. I can't imagine trying to operationalize that. We are using change of address as a triggering event even though I was against it. Some others we use:

1. Change in signatories.
2. At the AML Department's request (This is a catch all and meant to eliminate transactional thresholds which could become burdensome).

I think that when the front-end scramble to get all the pieces in place for this rule has subsided, one of the first things banks will do is re-think this list. With experience, they will get a better sense of what to look for. As for me (and I don't work in a bank, so take my opinion for whatever you think it's worth), a change of address should trigger some conversation before pulling a new BO certification form out of your filing cabinet. Companies do change addresses from time to time without changes in ownership. I agree, though, that you will need to ask.

Triggering events when there are multiple existing accounts is causing me some confusion. Let's say a legal entity customer (LEC) relocates or even notifies us of a change in ownership and this LEC has multiple accounts. We have the LEC sign one Certification Form. There is no new account opening. Does one Certification Form suffice? It seems completely unnecessary to have LECs sign multiple Certification Forms under these circumstances. How are others handling this?

We've had discussions about the following triggering events... are you guys getting CBO information at these times:
1. The ordering of a new debit card for a business after the account was opened
2. Subscribing to receive e-mail statements
3. Signing up for bill payment through online banking

Is this crazy?

1. no
2. no
3. no

yes, that is crazy in my opinion

When we are aware of a change, we would have the individual representing the LEC complete one certification form. It would get archived in our imaging system to all effected accounts. The form could be retreived by searching the customer's TIN or account numbers. That way the retention would be for 5 years after the account that was closed last.

That makes a lot of sense, bccompliance. Thank you.

Any thoughts on when an LEC has multiple auto-renew CDs that mature within a month or so of each other? Would one Certification Form suffice for all? We'd like to handle all of the CDs at once since they mature so close in date to each other. Again, seems crazy to have them sign four of the same form at the same time.

Our BO's are stored at the customer level where so far in the history of the bank nothing has ever been purged. Our PTB have decreed we will not ask for multiple BO's from a single entity for a single day's event.

We would collect one BO form and one form with all account numbers listed where the customer attests to contact the bank if any of the beneficial owner information changes.

Thank you for the input.

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