Is it possible for a business to have two control prongs? We have an instance where we have a business owner who owns 100% of the business. On the loan side, the beneficial ownership indicated that the person is both the BO and the control. Then they opened a deposit account and the business owner typically has his authorized person doing that so he was listed as the beneficial owner 100% and this person that we'll call secretary signed as the control person. Is this ok to do, or must they be consistent across each account?

Both the BO and controlling person are listed in our system under the organization level. So, for us it would have to be across the board, as there is nowhere to list two controlling people. The system does not allow this. Plus, I would still think the owner would be the controlling person in your case as he would be the person managing the business. The authorized person, I'm assuming, is simply an authorized person to transact on the account.

Control prong is for the overall entity, not the individual product. We would require consistency.

And while a secretary may "control" a business office, I doubt that it's a management-level position for the business. It's true that we are supposed to accept the information the entity supplies, but not when we have reason to doubt its accuracy.

Would be problematic for us as we only have one filed for the control prong in our core. We would have to get a new form to make them consistent.

I think it's normal in many cases for businesses to have multiple people who meet the definition of a control person (CEO and CFO, two managing members), and so I could see a case where every time they open a new account the person opening it may identify a different person. The way we handle this is that it's customer-level data, and the newest certification is the one we maintain, any changes replace the old information. Just keep record of all the changes along the way.

I agree with John in this case though. I would assume the customer misunderstood the question.

The way the regulation is structured, beneficial ownership data is supposed to be at the legal entity customer level. The opening of a new account is a triggering event to either gather that information for the first time or to update the information. The only reason accounts beyond that time is due to retention requirements, but so long as you maintain the BO data (and all of it's iterations at the entity level) for five years from the date that the last remaining account is closed, you'll be able to comply.

So, in your example, what ideally should have happened is that you had the authorized representative (after verifying their authority) confirm that the current BO data was accurate; or, provide you with the new data which would "overwrite" the last version.

If that person needed to be able to conduct transactions on the account, but the ownership didn't change, then you should just add them as an authorized signer.