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#2238669 - 06/25/20 05:48 PM BO Form Dated Before Account Opening Date
NoJustNo Offline
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Joined: Oct 2013
Posts: 193
Midwest
I'm starting to notice that some beneficial ownership forms are dated several months before account opening. Does anyone have any thoughts on a standard? Do you have it in your policy/procedures? I can see where a few days is reasonable but I'm seeing some that are three months (which makes me think they are being "resused."

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#2238755 - 06/26/20 09:58 PM Re: BO Form Dated Before Account Opening Date NoJustNo
NoJustNo Offline
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Joined: Oct 2013
Posts: 193
Midwest
Bump? I starting looking at the reg and it states that "the covered financial institution’s customer due diligence procedures shall enable the institution to: Identify the beneficial owner(s) of each legal entity customer at the time a new account is opened"

It seems to me that they should be dated the same date (or, at least, ensure they are received/"approved" by the beneficial owner on the day of account opening?

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#2238756 - 06/26/20 10:00 PM Re: BO Form Dated Before Account Opening Date NoJustNo
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,644
Galveston, TX
I do not understand why there is such a big difference in dates. Are these existing customers opening new accounts??
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#2238778 - 06/29/20 04:50 PM Re: BO Form Dated Before Account Opening Date NoJustNo
NoJustNo Offline
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Joined: Oct 2013
Posts: 193
Midwest
I don't either -- but i suspect they inquired about an account, completed the form, then didn't bother to come in/open the account for several months.

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#2238779 - 06/29/20 04:52 PM Re: BO Form Dated Before Account Opening Date NoJustNo
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 78,644
Galveston, TX
In that case, then ownership could have changed dramatically and a new certification should have been obtained.
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#2238797 - 06/29/20 08:19 PM Re: BO Form Dated Before Account Opening Date NoJustNo
Buddy the Elf Offline
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Buddy the Elf
Joined: May 2002
Posts: 972
first lily pad on the right
Our procedures have a maximum date difference of 30 days and is applicable to loans only. If the first BO form was dated more than 30 days from the closing date, they are required to get an updated form at closing. For deposit accounts, the date on the form is supposed to match the date the account was opened. We have had instances of folks in the field reusing the signature page from a previously submitted form and if we can identify it, we do require them to get a new one. But sometimes it's hard to tell, particularly if the signature page is conveniently missing the date that the customer signed the form. They definitely try to find ways to avoid having to obtain an updated signature.
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