Currently we require updated Articles of Incorporation when changing signers on a business account. We are now having push back from one particular member b/c they are an attorney and we "shouldn't need this to update signers". What does everyone else ask for when trying to update signers on a corporation?

A new corporate resolution. Why would they have to update their articles to appoint someone new to sign on a checking account?

All the original people listed on this particular Articles are deceased. Would that not need updated? I am new to this part of compliance and appreciate your input.

Not trying to be critical but this is not a compliance issue, this is a contract issue. First of all don't listen to your customer, the bank should determine what they want. Get a new Corporate Resolution identifying who can conduct transactions on behalf of the Company.

Agreed. Asking for revised Articles is overkill and overreaching. It also creates unneeded hassle for the customer. A certified resolution of the governing board (board of directors, typically) authorizing the addition or change is what you need, along with a signature of the lucky individual(s).

What is your opinion for a removed LLC member? For a new account, the Articles of Organization (dated less than a month ago) have two owners listed. The agent which is opening the account on behalf of the entity, said that one of the listed owners is no longer a part of the LLC. What is acceptable to verify this? A signed statement from the remaining LLC member? (This will be a high risk BSA account and we want to be as thorough as possible).

For a high-risk AML account, I'd want more than the statement from the agent concerning ownership. The LLC needs to produce documentation that one of the owners has left the entity.

You have a legitimate reason for requiring an updated Appendix A.

The irony is that the only triggering event under the regulation is the opening of a new account. There, the person authorized to sign is the person opening the account. If you ask for an Appendix A under other circumstances you are going to manufacture your own requirements for who signs the document.

Gone or not, the member is still a signatory on the account until you get a resolution from the LLC that says otherwise, but that's the LLC's issue, not yours. If John and I are the only members and I have "left the building" he's going to bring in a new resolution forthwith.

forthwith, PDQ and tout de suite.