I seem to be confusing myself on this one. Does a Revocable Trust need the Beneficial Ownership Certification, Reason for Not Needing CDD Certification of Beneficial Owners or nothing at all?

Thanks in advance!

A revocable trust is not a legal entity customer under the beneficial ownership regulations. See 31 CFR 1010-230(e)(1) and question 22 in FinCEN's July 2016 CDD FAQs.

If your customer is a legal entity with 25% or more of its ownership held by a trust, a trustee of that trust must be listed as holding that ownership (on behalf of the trust).

I agree with John Burnett. But let me also say that it sounds like you're referencing an internal form, in which case, you should refer to your policy.

On a similar note, in my humble opinion, I think it's a good practice to have an internal beneficial ownership form with something like the "Reason for Not Needing CDD" completed for each and every non-personal account. It's more work, but it simplifies the job for your business lines and first line of defense. And it helps the second line of defense identify training issues. And if monitored properly, it can prevent or mitigate audit/exam issues by having an explanation captured to support your getting no BO or only partial BO.

Thank you Pat & John for your responses. They definitely help! The form in question "Reason for Not Needing CDD" is actually from Walters Kluwer form and we do use it for Entities not needing CDD Ben Owners such as Associations.