Beneficial Ownership Exclusion

Posted By: JennKK2

Beneficial Ownership Exclusion - 10/23/19 04:06 PM

so we have a legal entity customer who meets the CDD exclusion rule due to the fact their common stock is listed on the stock exchange.
ok.
does that mean we are not required to get a control prong?
however
do we still need to have the person opening the account sign the form?
Posted By: BrianC

Re: Beneficial Ownership Exclusion - 10/23/19 04:13 PM

The customer is excluded from the rule. No certification form is required. How you notate in your due diligence that you consider the customer excluded to show auditors/examiners that you evaluated the beneficial ownership requirements is a matter of internal policy and procedure.
Posted By: JennKK2

Re: Beneficial Ownership Exclusion - 10/23/19 08:23 PM

thank you! and we did take notes thinking along the same lines as you suggested.