I'm betting that the bank's wish to get a checking account as part of the deal doesn't limit the use of the account to "receiving, disbursing or otherwise using the PPP loan funds." The bank wants the borrower to have some additional connection to the bank besides the PPP loan, in the expectation of something more substantial when the pandemic is behind us and the borrower is successfully recovering and perhaps flourishing as the economy regains some semblance of whatever the new normal becomes.
If that's the case, I don't see the response from FinCEN gives you cover to omit obtaining BO info for the deposit accounts.
But, if I am wrong, and the deposit account is just for disbursing the PPP proceeds (does that make it PPPP or 4P?), you're good.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8