We have a group of customers that together do not have significant ownership stake, but the intent of their loan is to buy out the other partners which would THEN make them have a significantly higher stake.
My question is- if I am reading guidelines- FinCEN requires the information at the TIME of the loan application correct?
So at the time of the loan application, we would not have anyone with over 25%, however if the loan goes through and is transacted, we would only have significant beneficial ownership for future accounts opened, correct?

We are required to obtain beneficial ownership information "at the time a legal entity opens a new account" or "when the bank has knowledge that beneficial ownership information has changed."

Since you have knowledge that ownership is changing as a result of the consummation of this transaction, you should be obtaining an updated certification at closing.