To our valued business customers:
We wanted to inform you of the recently issued Federal Rule that enforces all financial institutions to obtain certain paperwork not previously required. This regulatory rule strengthens due diligence requirements in an effort to defend against abuse by legal entities that commit terrorist financing, money laundering, tax evasion, corruption, fraud and other financial crimes. All financial institutions are required to identify, verify and maintain records of identification for beneficial owners.
The rule defines a legal entity client as a corporation, limited liability company, other entity created by the filing of a public document with a Secretary of State or similar office, a general partnership, and any similar entity formed under the laws of a foreign jurisdiction that opens an account. The definition also includes limited partnerships, business trusts that are created by a filing with a state office, and any other entity created in this manner. A legal entity client DOES NOT include sole proprietorship, unincorporated associations, or natural persons opening accounts on their own behalf.
Beginning in May 2018, banks will require certification from the individual opening a new business account on behalf of a legal entity; new accounts include deposit accounts, certificates of deposit (CDs), loans and safe deposit boxes. Certification will also be required at the time of renewal on CDs and loans. Certification consists of providing the beneficial owner(s) information (including identifying information and percentages of ownership) and the controlling party information.
Beneficial Owner is defined as each individual, if any, who owns, directly or indirectly, a select percentage of the equity interest of the legal entity client.
Controlling Party is defined as an individual with significant responsibility to control, manage, or direct a legal entity client, including an executive officer (CEO, CFO, COO, Managing Member, General Partner, President, Vice President or Treasurer), OR any other individual who performs similar functions.
Information required of Beneficial Owner(s) and Controlling Party is his/her legal name, physical address, Tax ID, date of birth, and government-issued photo identification.
Thank you for banking with us, contact your account officer if you have any questions.