Good Morning,

Does beneficial ownership rule apply to business credit cards? We are starting a business credit card program offering cards, so is that considered a new loan and subject to the beneficial ownership rule? Does it matter if it is a bank credit card or if we are selling on behave of a third party? Example: It would be Elan's credit card with the Bank's name on it.

Thank you,

I am really unsure how you get around the following as the customer nor the account is likely to be exempted. Who does it in a private label situation is really up to your agreement with Elan.


§ 1010.230 Beneficial ownership requirements for legal entity customers.

(b) Identification and verification. With respect to legal entity customers, the covered financial institution's customer due diligence procedures shall enable the institution to:

(1) Identify the beneficial owner(s) of each legal entity customer at the time a new account is opened, unless the customer is otherwise excluded pursuant to paragraph (e) of this section or the account is exempted pursuant to paragraph (h) of this section.