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#2224230 - 10/23/19 04:06 PM Beneficial Ownership Exclusion
JennKK2 Offline
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Joined: Nov 2006
Posts: 212
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so we have a legal entity customer who meets the CDD exclusion rule due to the fact their common stock is listed on the stock exchange.
ok.
does that mean we are not required to get a control prong?
however
do we still need to have the person opening the account sign the form?
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#2224231 - 10/23/19 04:13 PM Re: Beneficial Ownership Exclusion JennKK2
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,077
Illinois
The customer is excluded from the rule. No certification form is required. How you notate in your due diligence that you consider the customer excluded to show auditors/examiners that you evaluated the beneficial ownership requirements is a matter of internal policy and procedure.
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#2224284 - 10/23/19 08:23 PM Re: Beneficial Ownership Exclusion JennKK2
JennKK2 Offline
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Joined: Nov 2006
Posts: 212
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thank you! and we did take notes thinking along the same lines as you suggested.
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