Our second round of PPP loans will begin tomorrow. We are expecting the majority of these loans to be 2nd draws from the clients who we did the 1st set of PPP loans for. They will be new loans with new account numbers.

A few questions...

1) For these loans, will we need to do a recertification form if they are an existing client?

2) We may open deposit accounts for each one like we did last time, so would that change the requirement at all regarding beneficial ownership?

3) Several PPP borrowers opened deposit accounts with the first PPP loans and then CLOSED them after the funds were used. It would be swell if we could re-open those closed deposit accounts for this 2nd draw PPP loans rather than go through the whole deposit opening rigmarole again (or at least streamline it). How should we approach this, and if the accounts have to be re-opened, do we have to then get a whole new beneficial ownership form again?

1. FinCEN has not published anything since its April 2020 FAQs. Unless you hear differently, I would continue to follow these.

2. The FAQs do not extend to deposit account. A beneficial ownership certification is required when a legal entity opens a new deposit account.

3. It is a business decision. Personally, I prefer using a new account number to avoid any issues if the signers are different this time around, or if we receive any legal documents which impact the new account and not the old, etc. Beneficial ownership requirements apply regardless of which method you choose.