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#2198391 - 11/15/18 10:14 PM CDD
AubPeterson Offline
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Joined: Aug 2017
Posts: 7
Question. On business accounts must you get personal addresses on signers on the account? Do you need to do verification on the signers on the business account?
Thank you

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#2198393 - 11/15/18 10:21 PM Re: CDD AubPeterson
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
I am not aware of any regulatory requirement to do either, barring the fact that they are not also beneficial owners.
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#2198416 - 11/16/18 12:29 PM Re: CDD AubPeterson
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,658
I agree with Randy that there is not a regulatory requirement to get a personal address or conduct verification for a signer because a signer on a business account is not a "customer" under BSA rules. A "customer" must be verified, and your "customer" on a business account is the business entity, not the individuals. That said, and in addition to the BO rules Randy mentioned, there are two other instances where you would need the address of a signer: 1) if the "business" is not a legal person/entity (like a civic club - which really isn't a business) and 2) if your policy requires it.
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#2198542 - 11/16/18 09:28 PM Re: CDD AubPeterson
TryingtoComply Offline
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Joined: Apr 2013
Posts: 2,199
The West
Randy and Adam are correct that the BSA regulations do not require it, but if your procedure does, you should observe it.

Some banks require CIP information on authorized signers. I've worked for banks that do and banks that don't. For those that did, there were always authorized signers that had no ownership in the business that balked at the bank collecting information about them. Typically, HOA signers.

Hope that helps!
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#2198562 - 11/16/18 11:42 PM Re: CDD AubPeterson
Jessesgirl Offline
Member
Joined: Nov 2008
Posts: 54
There's No Place Like Texas!
[b]This is from the BO FAQ:

Question 5: Collection of beneficial ownership information: Required addresses

What address should be obtained for a legal entity customer’s beneficial owner(s)
to comply with the certification requirement – residential or business?

A. The address requirements for certification under the CDD Rule are the same
as those outlined in the CIP rule. For an individual beneficial owner, covered
financial institutions must obtain either a residential or a business street address.
If neither is available, acceptable substitutes may include an Army Post Office
(APO) or Fleet Post Office (FPO) box number, or the residential or business street
address of next of kin or of another contact individual.
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#2198574 - 11/17/18 07:11 AM Re: CDD AubPeterson
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Yes, and that is addressing beneficial owner requirements and not signatories on an account. They are different animals.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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