Posted By: chrise
Beneficial Ownership for a guarantor company - 09/12/19 01:13 PM
I have a loan to an LLC which is guaranteed by another LLC. Are we required to get BO of the guarantor company?
Posted By: ColoradoAML
Re: Beneficial Ownership for a guarantor company - 09/12/19 01:58 PM
According to regulation, no. You're required to collect on your customers. Customers, as defined in CIP, don't include guarantors.
Obviously if your policy says differently, you need to follow that.