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#2187589 - 08/01/18 04:27 PM Beneficial Ownership on Business Credit Cards
Snowgirl Offline
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Joined: Sep 2003
Posts: 729
Does the Beneficial Ownership rules apply to credit cards? I read this in the FFIEC Exam Manual for BO:

Exemptions and Limitations on Exemptions
Subject to certain limitations, banks are not required to identify and verify the identity of the beneficial owner(s) of a legal entity customer when the customer opens any of the following categories of accounts:
• Accounts established at the point-of-sale to provide credit products, including commercial private label credit cards, solely for the purchase of retail goods and/or services at these retailers, up to a limit of $50,000;

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#2187607 - 08/01/18 05:18 PM Re: Beneficial Ownership on Business Credit Cards Snowgirl
Buddy the Elf Offline
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Buddy the Elf
Joined: May 2002
Posts: 975
first lily pad on the right
Yes, credit cards that are co-branded with major credit card associations (MasterCard, Visa, etc) are subject to BO.

Page 80 of the Final Rule:
In contrast, credit cards that are co-branded with major credit card associations do not possess the same limitations and characteristics that would protect them from abuse. For example, co-branded credit cards can be used at any outlet or ATM that accepts those associations’ cards. FinCEN therefore believes that covered financial institutions should obtain and verify beneficial ownership information with respect to opening accounts for legal entities involving such co-branded cards.
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