Beneficial Ownership - Owned by SEC-registered Co.

Hi all,

We have an insurance company that is going through an internal shake-up and is changing signers/ownership as a result. We have already implemented informal Ultimate Beneficial Ownership (UBO)-gathering procedures that will be formalized for Jan 1. I just want to make sure I am only getting what I need here.

The Insurance Company is owned by an SEC-registered, publicly traded Corporation. One of the exemptions that I read for UBO is "Publicly held companies traded on certain US stock exchanges, and any majority-owned domestic subsidiary of any entity whose securities are traded on a US stock exchange". Would this fall into that category?

When I think this through, Section B (ownership) would be the Corporation - drilling down from there would mean the information is publicly available. So, therefore, it makes sense that UBO would not be required in this instance. But I am second-guessing myself as this is a unique situation for our small bank.

Any help would be appreciated.

Thanks

Insurance companies are excluded in their own right; this may be unnecessary.

If you are attempting to verify the existence of a subsidiary of a publicly traded company listed on a major exchange, your research would be the same as if you were trying to recognize them as an exempt person. You would go to the parent's form 10-K on the SEC web site and find your quarry on its list of subsidiaries.

If you want to avoid going through this exercise every time the sub opens an account, you will record its status at the CIF rather than the account level.

Thank you!