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
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8