I have the "ABC" Church of Christ that owns and runs a private school, "ABC"Christian Academy Inc, on the church grounds.
The church will be exempt from the beneficial owner requirements, but do I need to obtain paperwork for the private school since it is a subsidiary of the church?

On what do you base an exclusion for the Church? Is it simply not a legal entity formed by filing with the state SoS?

The school, however, appears to be an entity (the "Inc." suggests strongly it's a corporation). If it opens an account with you (including borrowing, leasing a safe deposit box, etc.), it's subject to the B.O. requirements. Assuming that it's a non-profit corporation, that has filed its organizational documents with the SoS or other appropriate authority, it will only have to provide the name and ID info for the control prong. It will not need to provide the ownership prong info.

Sorry new to this and filling in for our CIP auditor who is out.

I am excluding the church based on the church being a non profit organization that is not incorporated. Is this not correct? Control prong is always required- correct?

Thanks for taking the time to help me. I appreciate you.

And you can believe me when I say I'd rather you ask the questions before making the wrong decision than beg forgiveness of your examiner later.

If the church is incorporated and nonprofit, it's subject to the E.O. rule, but does not need to provide info on the ownership prong (it has no equity owners). It will provide a control prong individual's name and ID info. If it is not incorporated, it is excluded from coverage of the rule altogether -- no ownership info, no control prong info.

If the church has a subsidiary (the school mentioned in your first post), the subsidiary stands on its own. Whether the church is subject to the rule or not will be irrelevant.

Great explanation, John. Said another way, there are two types of non-profits - incorporated and unincorporated. Incorporated nonprofits are subject to the BO rules (and control prong) because they are first considered a legal entity (i.e. incorporated) and only secondly viewed as a nonprofit. Unincorporated non-profits are not subject to the BO rules because they are not viewed as a legal entity. Therefore, the nonprofit status has no bearing on the BO applicability.

From the preamble to the final rule:
"This is because neither a sole proprietorship nor an unincorporated association is an entity with legal existence separate from the associated individual or individuals that in effect creates a shield permitting an individual to obscure his or her identity. The definition of “legal entity customer” also does not include natural persons opening accounts on their own behalf.”

The more ways this can be explained, the better the chance that it will drive the point home with bankers.