Answer:
by Ken Golliher:
No bank employee would ever sign the form.
The signatory is the individual opening the account. If the individual across the desk and providing the documentation is a beneficial owner, she would sign it. If the individual is nothing more than the company's "runner," he would sign it.
Answer:
by Jim Bedsole:
We trained that the person signing the beneficial ownership form would be the same person that would be signing the signature card or loan documents, and as such, should be a person named in entity documents (such as a corporate resolution) as having authority to sign bank documents on behalf of the company. That may be too conservative of an approach for some, but that's the approach we have taken.
Answer:
by Ken Golliher:
Banks are entitled to their own requirements. Some say that the person named in the corporate resolution who is empowered to open the account (may or may not be a signatory) is the person who is required to sign Appendix A. That would be my choice.
FinCEN has no requirement beyond saying that the natural person (as opposed to an unnatural person?) opening the account should sign.
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