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#2221460 - 09/12/19 01:13 PM Beneficial Ownership for a guarantor company
chrise Offline
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Joined: Jan 2019
Posts: 2
I have a loan to an LLC which is guaranteed by another LLC. Are we required to get BO of the guarantor company?

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#2221463 - 09/12/19 01:58 PM Re: Beneficial Ownership for a guarantor company chrise
ColoradoAML Offline
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Joined: Mar 2018
Posts: 240
According to regulation, no. You're required to collect on your customers. Customers, as defined in CIP, don't include guarantors.

Obviously if your policy says differently, you need to follow that.

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