I'm curious how other banks are handling Beneficial Ownership on denied loans? Is it part of your application process or do you get before consummation of loan? Thank you!!

We may well have obtained it at the point of turndown. In which case I'm sure it would be in the turndown file, but I don't know what else would become of it. It wouldn't go on our system.

We have trained our RMs to obtain the form during the application phase. Docs cannot be ordered without it. If an application is denied, it would be retained in the decline file and destroyed in accordance with our retention schedule.

Since a denied loan does not meet the definition of "account" the conversation is not relevant. If you obtained information at application, that's fine. If you did not obtain information at application, that is fine, too. Refer to your institution's procedures and make sure you follow them. The final rule requires that we identify beneficial owners at account opening.