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#2218087 - 07/19/19 09:00 PM Beneficial Ownership on Grantors
Nicole Offline
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Joined: Nov 2018
Posts: 158
Hello, we have a loan that we are doing on a individual no business entity involved as borrower or account owner, however the collateral we are taking is "owned" by a LLC (just collateral grantor). Do we need to do beneficial ownership for the entity if they are not a "borrower" or "account owner"?

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BSA/AML/CIP/OFAC Forum
#2218090 - 07/19/19 09:19 PM Re: Beneficial Ownership on Grantors Nicole
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,716
Illinois
The grantor is not your customer and therefore not subject to CIP or CDD requirements.

BSA responsibilities aside, hopefully there is something in your underwriting procedures about verifying that the representative of the LLC signing the collateral agreement has the authority to do so in the LLC resolution of authority, operating agreement, etc, lest you have some random person pledge collateral for which they do not have the authority and you find yourself with a useless collateral agreement.
Last edited by BrianC; 07/19/19 09:22 PM.
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#2218091 - 07/19/19 09:24 PM Re: Beneficial Ownership on Grantors Nicole
Nicole Offline
100 Club
Joined: Nov 2018
Posts: 158
Thank you i appreciate your help!

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