Certification of Beneficial Ownership Form

Posted By: BSAGal

Certification of Beneficial Ownership Form - 05/15/19 01:11 PM

Good morning - we are using the model form, obtaining ownership of 25% or more. In some instances customers have listed owners with less than 25% on the form. Is there any reason we could be criticized for this? Is it necessary to obtain a new form? I see no harm in listing those with less than and just see it as additional information, but wanted others opinion. We have yet to go through an exam on beneficial ownership. Thank you.
Posted By: ColoradoAML

Re: Certification of Beneficial Ownership Form - 05/15/19 05:12 PM

If it were me, I wouldn't be overly concerned. In my opinion, the argument then you would be inconsistent or arbitrary shouldn't apply because this is information supplied by the customer, and it's clearly not what you're requesting (which is all written on the same form). I'd also hope that examiners would understand the absurdity of returning to and inconveniencing your customers just because they told you more information than you asked for.