Beneficial Ownership and Trusts

We have an LLC that is owned by "A" Trust 25%, "B" Trust 25%, and Individual 25%. No other ownership is greater than 25%.

So for Beneficial Ownership I would would include:
Name: "A" Trust.
Ownership %: 25%.
CIP at least one trustee

Name: "B" Trust.
Ownership %: 25%.
CIP at least one trustee

Name: Individual
Ownership %: 25%.
CIP Individual

Question: if there are multiple trustee - do I have to have the ownership % of all trustees to answer the Ownership %.

Thx!

Trustees do not own a trust - it is its own entity - nobody owns it.

Thanks! I think I understand.

I would just put Individual, A, B = 25%.

Then just CIP one of the trustees for each trust???

Is that correct?

See questions 19 & 20: https://www.fincen.gov/sites/default/files/2018-04/FinCEN_Guidance_CDD_FAQ_FINAL_508_2.pdf

Thanks rlcarey!

I read the Q&A but I guess I am uncertain more specifically - how do I complete this section of the form for the trust?

This addendum should be used when there is legal entity or entities that owns 25% or more of the legal entity customer opening this account.

Legal Entity Name: Trust A
% Ownership in Legal Entity Opening the Account: 25%

Name: Trustee
Date of Birth: 123
Address: 123
For U.S. Persons: Social Security Number: 123
For Non-U.S. Persons: Passport Number and Country of Issuance, or other similar identification number
Ownership %: ?????

Beneficial owners have to be natural persons. You don't have to list the trust anywhere. You list one of the trustees.

One way to simplify your process is to not actually track the percentages, just know that if someone is listed they represent 25% or more.

If a trust owns 25% or more of the legal entity, you do not identify the trust as the beneficial owner. You identify a natural person who is a trustee of the trust.

John Jones, Trustee
John Jones's personal info