This is probably more a "Newbie Nook" style question, but I'm trying to deal with a beneficial ownership issue and this one (which probably isn't too difficult) goes beyond my level of comfort/familiarity with the rule and its underlying logic (which are minimal, at best).

Basically, we have two beneficial owners. For the B.O. I'm asking about, his residential address is evidenced by an expired lease agreement. We also have a current driver's license for this B.O., but it doesn't have his residential address on it. It also seems we're unable to obtain other documentation with his name on it, such as a utility/phone bill, etc.

To add a wrinkle, I believe this B.O. resides with the other B.O. I'm not sure whether that makes this simpler or more complex.

Our procedures stipulate that "100% of the beneficial owner and/or controller information needs to be authenticated." Are there other ways we can verify/authenticate this B.O.'s residential address? Some kind of affidavit? If we cannot, does this ultimately become a business decision?

So you B.O. has no documents that reflect an address? No tax documents, no employment documents, bank statements, etc.? I would be very reluctant to violate my established procedures. It seems strange to not be able to find something establishing residence.

Hi Kimo, thanks for your response. As a person who tries to call it like I see it, but also to sometimes "make things work," that became my take, too. Happy Friday the 13th!

Happy Friday the 13th with a full moon!

Happy Monday the 16th!...OK so that doesn't mean anything, but happy to help in any way I can!

late to the party - but I heard a full moon on Friday the 13th wont happen again until 2042?

in addition, I agree with kimo in Idaho. there ARE other documents but again you need to rely on your bank's CIP policy.