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In Response To:
Thread Starter: Justin Case
Title: Re: Verification of identity of Beneficial Owners

We do non-documentary ID verification for Beneficial Owners who US citizens and are not customers. It's not a credit pull, it is ID verification and OFAC only. The ID verification report is scanned into our archive system along with the Beneficial Ownership form.

If non-doc ID verification fails, we require a copy of the driver's license, passport, etc (dependent upon what the failure was) and record all of the required information (doc type, doc number, state issued, issued date, expiration date). We do not retain the copy of the document, only the description. For non-US citizens who are not customers, we require a copy of the passport and have a checkbox on the Beneficial Ownership form that the passport was viewed.