A not for profit corporation is a legal entity customer. It is not exempt. The regulation, however, lowers the bar for such a group, and requires only that the Beneficial Ownership Certification ("BEC") identify a Control Person. See 31 CFR 1010.230(e)(3), which provides that special rule also for "a pooled investment vehicle that is operated or advised by a financial institution no excluded under paragraph (e)(2)."
Most non-profit corporations have no shareholders or owners, so even if paragraph (e)(3) didn't exist, their BECs would not show any individuals as owners, but would include a control person. FinCEN may have included paragraph (e)(3) so that bankers seeing such BECs would not look at them thinking "This can't be right. Where is the ownership info?"
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8