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#2185738 - 07/17/18 07:32 PM Beneficial Ownership Form
Compliance Lover Offline
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Just curious if most are including account number(s) on the beneficial ownership certification form or using the entity's tax ID number to identify. Some forms have this as an optional field.

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#2185739 - 07/17/18 07:42 PM Re: Beneficial Ownership Form Compliance Lover
Complycated Offline
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Our software automatically includes the account number on the form.

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#2185748 - 07/17/18 07:50 PM Re: Beneficial Ownership Form Complycated
Compliance Lover Offline
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That would be nice.

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#2185876 - 07/18/18 04:09 PM Re: Beneficial Ownership Form Compliance Lover
Sunshine Lady Offline
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We formatted our form to include the account number.
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#2185901 - 07/18/18 05:30 PM Re: Beneficial Ownership Form Compliance Lover
one deer Offline
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Any where but work
Account number may be included, but not required.

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#2185963 - 07/18/18 07:56 PM Re: Beneficial Ownership Form Compliance Lover
ahkcompliance Offline
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Joined: Sep 2008
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Midwest
We are listing the account number.

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#2185970 - 07/18/18 08:12 PM Re: Beneficial Ownership Form Compliance Lover
Daisy Doodle Offline
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Southern U.S.
Our forms vendor has not yet put the account number on, but we are hoping that will be coming. Right now, just the EIN.

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#2186083 - 07/19/18 04:50 PM Re: Beneficial Ownership Form Compliance Lover
RHG45 Offline
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We include the acct number on our form to show proof of ben owner compliance during the trigger event (new account)

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#2186085 - 07/19/18 04:53 PM Re: Beneficial Ownership Form Compliance Lover
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Acct number

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#2186354 - 07/20/18 09:11 PM Re: Beneficial Ownership Form Compliance Lover
TryingtoComply Offline
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The West
As "R" said, we include to demonstrate that the form was obtained in connection with a triggering event -- a new account. If you have a customer that opens numerous accounts (we have many), how will you prove that you met the requirement for a particular account?
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#2186407 - 07/23/18 02:12 PM Re: Beneficial Ownership Form Compliance Lover
Cbecotte Offline
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Joined: Jun 2009
Posts: 72
Massachusetts
We are using account number also.

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#2186408 - 07/23/18 02:20 PM Re: Beneficial Ownership Form Compliance Lover
rlcarey Online
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So you open an account for XYZ, Inc. on 07/01 and you get BO information. On 08/01 you open another account for the same company and get BO information. So, if the ownership of XYZ, Inc. changed between 08/01 and 07/01 - how do you reconcile that with the information you have on file for the first account?
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#2186484 - 07/23/18 06:00 PM Re: Beneficial Ownership Form rlcarey
Buddy the Elf Offline
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Originally Posted By rlcarey
So you open an account for XYZ, Inc. on 07/01 and you get BO information. On 08/01 you open another account for the same company and get BO information. So, if the ownership of XYZ, Inc. changed between 08/01 and 07/01 - how do you reconcile that with the information you have on file for the first account?


Our form also has a place for the account number. The forms are stored under the entity's EIN. So our stance is that the most recent signed form on file for that EIN trumps the others.
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#2186491 - 07/23/18 06:47 PM Re: Beneficial Ownership Form Compliance Lover
JennKK2 Offline
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Posts: 364
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our vendor forms include account number field. if multiple accounts are opened at same time we are simply writing the additional account numbers on the same form. the EIN field is also populated in
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#2186501 - 07/23/18 07:05 PM Re: Beneficial Ownership Form Compliance Lover
TryingtoComply Offline
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The West
I agree with Justin Case. I believe this was FinCEN's intention. The most recent CBO is supposed to have current information regarding beneficial owners. Each time you open a new account it's an opportunity to make sure the information is correct.

Note, that I don't agree with all this...... it's just what I think they intended.
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