We recently had a BSA audit and the auditor put a recommendation in our final report to be more specific with the Title of the individual in the control prong section of the beneficial ownership form. Things like "Member" and "Owner" are not specific enough. Just curious what kinds of titles are specific enough and what you all are seeing. Thanks.

We have Member and Owner provided for titles. We have not received criticism as of yet.

Did your auditor just not have anything better to write in the report? The entire purpose of beneficial ownership is to enable law enforcement to know who they need to talk to about an entity. There aren't any other Brian Crows in my company so whether I am listed as "Member" or "Executive Vice President" I'm going to be pretty easy to find.

Internal audit, outsourced audit, etc.?

I'm not sure what the auditor thinks would be more specific?

Also, did the auditor provide a cite or source for this recommendation?

Just playing the big bad auditor side, if a legal title is different elsewhere why would you not use it for consistancy?

FWIW: Member may be the best title for a LLC and owner may be best for Sole P. but for corporations there may be better titles.

And congratulations if this is all that they found good job.

It's been almost 3 years since the last post on this subject - listing the word "member" as the individual with significant responsibilities for managing the legal entity customer - and I wanted to check in to see if anyone has received any additional comments on this issue from an examiner or auditor. It would be a picky finding to be sure but who knows when someone a tad overzealous could opine that the FAQ uses the term “examples of the types of positions” and be critical that the term “member” isn't a “high level official in the legal entity”. Oh well, it's a slow Tuesday.

I don't think there is a distinction between members and "owners" of LLCs, so I can't imagine someone questioning that a member identified on a BO certification didn't have a sufficient level to be named.