Another B.O. Question

We have an incorporated business doing business as assumed name (i.e. This Business Inc DBA Business Business), do we need a beneficial ownership form for both?

Business Business does not exist other than on a fictitious name certificate.

Ok, so then we only need the one BO form, right (for This Business Inc)? Our internal auditor is telling us otherwise.

Your auditor needs to understand the legal concept of an "entity." In your example, This Business Inc is a corporation, a form of legal entity. " Business Business is simply a nickname under which This Business Inc does business. The corporation is your customer. The fact that an entity using a trade name other than its own must, in some states, register that fact with a state office (often the Secretary of State's office) does not mean that the trade name has its own separate legal existence.

Correct. Only one form. An assumed name is just that, a name... on paper only... that's it.

There is a caveat to all this due to common errors I see on the front-line. There is a possibility that your customer wanted their account titled something like: Business Inc DBA Business2 Inc. If that error was made, where two separate businesses exist when there truly isn't a DBA present, I could see confusion. But that doesn't seem the case here, pretty black and white.

There are times when what the customer wants should not be what the customer gets. Remember that you are required to reflect the real ownership of an account in the bank records.

Thank you all, I appreciate the insight and help!