Beneficial ownership certification

Posted By: Anonymous

Beneficial ownership certification - 04/22/21 07:56 PM

I am confused regarding the completion of a certification of a beneficial ownership document for our Bank. We are attempting to change the signers on a correspondent Bank account. We checked the exempt box and listed that we were a U .S regulated financial Institution and used the President/CEO as the Natural Authorized Person Section of the document. The correspondent Bank is stating that we need to complete the owner ship percentages. We are a independent Bank with numerous shareholders. Am I missing something.
Posted By: RR Sarah

Re: Beneficial ownership certification - 04/22/21 08:03 PM

Is the bank owned by a holding company?
Posted By: Anonymous

Re: Beneficial ownership certification - 04/22/21 08:06 PM

No
Posted By: RR Sarah

Re: Beneficial ownership certification - 04/22/21 08:16 PM

I guess it doesn't matter either way..regulated banks and bank holding companies are both exempt from the beneficial ownership rules.
Posted By: Anonymous

Re: Beneficial ownership certification - 04/22/21 08:25 PM

Thank you for confirming that I am not losing my mind.
Posted By: ACBbank

Re: Beneficial ownership certification - 04/22/21 11:28 PM

Certain institutions, as a matter of policy, may still require this information. I know many banks that require listing of all beneficial owners of 10% or more.

FWIW I don't see the value in getting BO information from a regulated bank.
Posted By: edAudit

Re: Beneficial ownership certification - 04/23/21 01:15 PM

This is an evolving story.

https://www.fincen.gov/news/news-re...ocess-new-beneficial-ownership-reporting

https://www.federalregister.gov/doc...rship-information-reporting-requirements