Customer came in to open an account for ABC LLC.

The sole member of ABC LLC is XYZ Limited Partnership.

There are three partners in XYZ Limited Partnership. Fred Flintstone Irrevocable Children’s Trust is a 60% Partner. The other 3 partners own less than 25%.

The Guarantors of the Fred Flintstone IRR Children’s Trust are Fred Flintstone and Wilma Flintstone – both still alive and well in Bedrock.

The Trustee’s of the Fred Flintstone Irr Children’s Trust are Barney and Betty Rubble.

Question: Who do we name as the Beneficial Owners of ABC LLC since the trust is irrevocable? Fred and Wilma? Or Barney and Betty?

See Question #19 of the FinCEN FAQs. Simply put, pick one of the trustees. In addition to one of the trustees, you must also identify one control person.

Question 19: Collection of beneficial ownership information: Trusts with multiple trustees When 25 percent or more of the equity interests of a legal entity customer are owned by a trust that is overseen by co-trustees (multiple trustees), are covered financial institutions required to identify and verify the identity of all co-trustees?

A. No. If a trust owns directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise, 25 percent or more of the equity interests of a legal entity customer, the beneficial owner under the ownership/ equity prong is the trustee. Where there are multiple trustees or co-trustees, financial institutions are expected to collect and verify the identity of, at a minimum, one co-trustee of a multi-trustee trust who owns 25 percent or more of the equity interests of a legal entity customer that is not subject to an exclusion. A covered financial institution may choose to identify additional co-trustees as part of its customer due diligence, based on its risk assessment and the customer risk profile and in accordance with the institution’s account opening procedures.