Okay, so I know there are a few threads out there covering IOLTA's and Beneficial Ownership. Having said that, we have a non-profit customer that consists of many different law groups and it is confusing me with respect to collecting BO information. Here is the example:
1. Law Foundation is a non-profit with the board made up of attorneys from different law firms throughout the state
2. Law Foundation sends paperwork with Law Firm Customer A and they open account under the Law Foundation account as a subaccount. Firm Customer is not the primary.

Do we collect BO information on the Foundation and the Firm? I understand the FinCEN guidance on if the attorney opens up the account under themselves, but this is ran through an intermediary. Help appreciated!!!

We are looking at the Foundation and not the individual accounts. There's a lack of guidance regarding this topic so we decided to treat the foundation as the agent and IOLTAs subaccounts for purposes of beneficial ownership identification.

Interesting scenario for IOLTA accounts. Just curious - what State is this?