In May 2016, the U.S. government passed a new regulation regarding the beneficial ownership of legal entity customers. Going forward, it will be mandatory for all financial institutions to comply with this regulation by identifying the ultimate beneficial owner(s) and a controlling person of a legal entity customer opening or maintaining an account.
In compliance with this new regulation, Beacon Business Bank ("BBB") will collect beneficial ownership information from legal entity customers starting on April 16, 2018. This means that any time an account is opened or maintained for a legal entity, we will request information that identifies the ultimate beneficial owner(s) and controlling person of the legal entity.
What Information Do I Have To Provide
The required identifying information requires you to provide the name, address, date of birth and Social Security Number (or passport number or similar information, in the case of Non-U.S. persons) for the following individuals (i.e. the beneficial owners):
- Each individual, if any owns, directly or indirectly, 25% or more of the equity interests of the legal entity customer. We ask for loan borrowers to provide us with each individual, if any, who owns, directly or indirectly, 20% or more of the equity interest of the legal entity customer; and
- An individual with significant responsibility for managing the legal entity customer (e.g. Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President or Treasurer)
What you need to know about Beneficial Ownership
- The new regulation impacts all legal entities opening or maintaining accounts at any financial institutions. Legal entity includes a corporation, limited liability company, or other entity that is created by a filing of a public document with a Secretary of State or similar office, a general partnership, and any similar business entity formed in the United States or a foreign country. Legal entity does not include sole proprietorship, unincorporated associations or natural persons opening accounts on their own behalf.
- Legal entities will need to identify and attest to all ultimate beneficial owner(s) that meet specific requirements as well as a controlling person (e.g., Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President or Treasurer).
- Beacon Business Bank will collect information regarding the ultimate beneficial owner(s) and control person of legal entities whether or not they have a personal relationship with the financial institution.
- This information will also be collected for existing legal entity customers who establish or maintain accounts once this new regulation is implemented at Beacon Business Bank starting on April 16, 2018.