Smith Investors LP owns multiple commercial real estate buildings. They maintain several loan and deposit accounts with the Bank, all of which were established prior to the Beneficial Ownership Rule. They purchase a new building, ABC LLC and request to establish 50 tenant accounts.

-Should the master account always be set up in the name of the building LLC?
-Is beneficial ownership triggered only on ABC LLC?
-Would beneficial ownership be triggered for Smith Investors LP only in the event they request to establish a new account in its own name (e.g., operating account, loan) or has another bank-defined triggering event (e.g., change in ownership)?

Assuming the tenant accounts are escrow accounts to hold the tenants' security deposits and last month's rent, the master account should always be in the name of the party holding and administer the deposits, typically the landlord. If that person is a legal entity, it is the bank's legal entity customer, and you obtain BOC from that entity.