LLC Operating Under Another LLC

This is something that does not come across my desk everyday.

We have LLC 1 as an existing customer.

Owners of LLC 1 have formed LLC 2 and have quitclaimed property from LLC 1 to LLC 2.

We have a banking resolution from LLC 2 authorizing LLC 2 to open accounts.

LLC 2 does not have an EIN number, but will operate under the umbrella of LLC 1 and its EIN.

Who is our customer and who do we collect beneficial ownership information on?

I am leaning toward that we open an account for LLC 1 doing business as LLC 2, with LLC 1 being our customer and tax responsible party.

If that is the case, we would obtain beneficial ownership information on LLC 1.


On the other hand, if LLC 2 had their own EIN, I would say open the account for LLC 2 only, and collect beneficial ownership information on it.


Opinions?

The owners have formed a separate LLC or LLC 1 has formed LLC 2 and it is a sole member disregarded entity of LLC 1? Or is this some sort of series LLC? This is going to be based on State law and I suggest running it by legal counsel.

The owners formed the separate LLC.

It is not a series LLC.

Then it is totally a separate entity from LLC 1 requiring its own EIN.