Company A opens a new loan and lists the owner's son as the control person. A few days later, Company opens a checking account and lists the owner as the control person. Is there something in the rule that I don't remember that says the control person must be the same for different accounts? I think this is the first instance where we've run into this situation. What are other banks doing in this situation? And if you're listing multiple control people, do your core systems have trouble with that? And has anybody doing that been criticized by auditors/examiners?

FYI Company A and its owner are well-known and well-respected, no suspicious of any wrongdoing.

There is no requirement that says all accounts for a business need to have the same control person.

Just remember, the person identified for the Control Prong is supposed to be someone in charge of the entity, not someone in charge of the account (unless that's the way it works out).

For example, if your entity customer has its corporate offices outside your trade area and you have an account for one of its retail stores (the business isn't listed on an exchange, so it's not exempt), the control person should be someone at the corporate level, not the local manager with signature authority on the account.

We now have a second company/customer in the same situation. Multiple loans/DDAs opened over time. The various authorized people who are opening the different accounts list the CEO, the COO, and the finance director as the control person on different certifications. The customers don't care about BO, and I'm sure they don't try to remember which senior executive they listed on a certification 6 months ago. Our issue is that our core only will allow one individual to be listed as a control person. So if a company lists various people as control person over time on their certifications, the current CIF is not going to match the older certification, even though it matched at the time the account was opened.

I'm wondering if anybody has had auditors/examiners who had concerns about situations like this. How are banks handling it?

I wouldn't expect an examiner having concerns about this. Many entities have many control people, your job is only to ask them to identify one.

Our system only allows one control person as well, if they identify someone different, we update the record with the new one because that's the most current information we've been given. If you don't want to do this, you could consider implementing a different procedure where you ask the customer to verify if the information they provided you last time is still correct and document that or update as necessary, rather than simply asking them to provide information another time.