I hate to even post this but here goes. Is Beneficial ownership required on owners who are REITs? Technically they are not true trusts.
Thanks.

I need some help with that acronym. I don’t know what is stands for.

Real Estate Investment Trust

Private, public, traded - what type of REIT?

Private.

Bumping so RLCarey will see again.

Since they are not publicly traded, they really become similar to a limited partnership. You need to find out if someone owns more than 25% of the REIT. Just curious - what sort of account are they opening and what is it's purpose?

It is a loan. Not sure purpose.

Bumping this to confirm.

Confirm my thinking:

REIT owns two LLCs for two separate properties and want to open accounts for both LLCs. Both LLCs must be registered and have their own TINs? Beneficial ownership form should just reflect whether anyone owns 25% of the REIT (private REIT). They aren't treated like a true trust for BO.

I'm asking all these questions because the REIT is trying to tell us that they don't need to register the LLCs and want to use REIT DBA ABC LLC and use their own TIN. I disagree and I'm pretty sure no state allows that. Then the follow up question would be, the BO Form.

Let me rephrase. If they are disregarded entities. It can be done, I am not sure that is what is happening here. I just want to advise my front line on documentation we need to move forward.

It's my understanding that a disregarded entity can use the TIN of the parent entity. As for registration, I would expect them to be registered per our policy, regardless if there's a state that doesn't require disregarded entities to register.

It's also my understanding that ownership of a disregarded entity is the same as the ownership of the parent entity, so I agree with you that asking for BO of the LLC and asking for BO of the REIT are the same question.

EDIT: The question of who are the owners is the same, but my BO cert form lists the customer, and that would list the LLC, not the REIT.

I agree with Colorado. I also know of no States in which you can form an LLC and not register it with the State regardless of the fact that it might be a disregarded entity or not..