Don't expand your definition of legal entity customer beyond the FinCEN definition. From 31 CFR 1010.230(e)(1):
Legal entity customer means a corporation, limited liability company, or other entity that is created by the filing of a public document with a Secretary of State or similar office, a general partnership, and any similar entity formed under the laws of a foreign jurisdiction that opens an account.
The social organizations, if not incorporated as described in that definition, are not legal entity customers, and registering a trade name with the SOS does not create a legal entity.
Registration of a trade name does not make these organizations subject to the beneficial ownership rule.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8