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#2243640 - 10/06/20 07:43 PM Beneficial Ownership Form Required?
complofcr Offline
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Joined: Apr 2010
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SE USA
I haven't found where an actual form is required for Beneficial Ownership. Have I overlooked that somewhere? While doing an internal review I ran across some forms that were incomplete and incorrect (missing date of birth, DL number in the SS number block). While not having it correct is a pet peeve of mine, the information was obtained, we have copies of everything and have the information loaded correctly in our system. It just wasn't listed or correct on the form. How would you handle this? Of course, I'm going to provide additional training and make the employees aware of the mistakes, but is it something that we would need to get a new form completed and signed by the customer for?

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#2243642 - 10/06/20 07:48 PM Re: Beneficial Ownership Form Required? complofcr
John Burnett Offline
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John Burnett
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How can you have a certification of information that was not on, or incorrect on, the form? How can the bank be verifying the identity of beneficial owners without the required info?

The "form" doesn't have to be the one in the appendix to the rule, but it does need to include the information required by that sample.
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#2243650 - 10/06/20 08:07 PM Re: Beneficial Ownership Form Required? complofcr
complofcr Offline
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Joined: Apr 2010
Posts: 180
SE USA
Thanks John! I feel the same way. It's like the employee nor the customer is reading the forms, just signing away! The response I've been given is that the identity was verified when we got a copy of the drivers license, social security card, LLC documents, etc.
We're a very small bank in a very rural area. We've had less than a handful of entities that weren't 100% single member LLCs or 50/50 partnerships so they're not complicated. Just trying to see what needs to be done to the 20 something forms I have that need to be corrected.

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#2243692 - 10/07/20 02:17 PM Re: Beneficial Ownership Form Required? complofcr
John Burnett Offline
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John Burnett
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"It's like the employee nor the customer is reading the forms, just signing away!"

Yes, just like at most new account "events" and even mortgage closings at most banks. Your new accounts folks should be guiding customers through the process.

"The response I've been given is that the identity was verified when we got a copy of the drivers license, social security card, LLC documents, etc."

Is your bank's CIP procedure for verifying identity on new individual accounts similarly relaxed?
Last edited by John Burnett; 10/07/20 02:20 PM.
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#2243693 - 10/07/20 02:23 PM Re: Beneficial Ownership Form Required? complofcr
John Burnett Offline
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John Burnett
Joined: Oct 2000
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Cape Cod
If you have only 20 or so poorly completed certifications, you've got a good set of examples you can use in training sessions for your staff. They need to know that getting this stuff right the first time reflects well on their and the bank's professionalism. Having to go back to the customers after the fact to clean things up presents a less professional image.
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