This is something that does not come across my desk everyday.
We have LLC 1 as an existing customer.
Owners of LLC 1 have formed LLC 2 and have quitclaimed property from LLC 1 to LLC 2.
We have a banking resolution from LLC 2 authorizing LLC 2 to open accounts.
LLC 2 does not have an EIN number, but will operate under the umbrella of LLC 1 and its EIN.
Who is our customer and who do we collect beneficial ownership information on?
I am leaning toward that we open an account for LLC 1 doing business as LLC 2, with LLC 1 being our customer and tax responsible party.
If that is the case, we would obtain beneficial ownership information on LLC 1.
On the other hand, if LLC 2 had their own EIN, I would say open the account for LLC 2 only, and collect beneficial ownership information on it.