When collecting beneficial ownership for a DIP account, I'm leaning toward identifying the BOs of the bankrupt entity. I also believe listing the debtor as the control person would be reasonable.

Does anyone agree or disagree? Has anyone seen or obtained any guidance?

Who is opening the account? Who is your customer for CIP purposes? The bank should not be “putting” anyone down for either prong. We ask the person opening an account on behalf of a legal entity.

If the bankrupt party is an entity customer under the BO rules, it's likely that the same individuals would be listed (by the entity's representative in opening the account) for the DIP as for the entity before the bankruptcy.