What is Beneficial Ownership and why are these changes occurring?
On July 11, 2016, new rules under the Federal Bank Secrecy Act went into effect. These new rules aid the government in the fight against crimes to evade financial measures designed to combat terrorism and other national security threats. Pentucket Bank is putting this rule into effect on April 1, 2018, as all banks must implement these rules no later than May 11, 2018.
For the purposes of this rule, it simply means a person who, directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise, owns 25% or more of the ownership interests of a legal entity.
No. If you are a Sole Proprietorship, the account opening process has not changed for you. This rule generally applies to Corporations, LLC’s, Limited Partnerships, General Partnerships and Business Trusts. It does not typically apply to Unincorporated Associations, most Non-Profits, and Personal Trusts.
Each owner (25% or more ownership) will need to provide their: Name, Address, Date of Birth, Social Security Number. In addition, we will need one form of Primary Identification AND one form of Secondary Identification. The accepted forms are:
Current Primary Identification Documentation
- State Issued Driver’s License with photograph
- U.S. Government Issued ID with photograph
- U.S. Passport with photograph
- U.S. Issued Armed Forces / Military ID with photograph
- State Issued Identification Card with photograph
- Non-Resident Alien Identification Card w/ photo and number; together with a secondary ID.
- Employment Identification Card with photograph
- U.S. Military Dependent Identification Card
- Social Security Card
- School Identification card with photograph
- Major Credit Card
- Automobile Registration
- Union Card
- Utility Bills
- Original Birth Certificate
- For lending relationships, secondary identification is satisfied through additional documentary reviews.
This is the person within the management structure who has significant responsibility to control, manage or direct the business. While there may be multiple people who can and will control the entity, we will require one individual.
Common examples: An executive officer or senior manager (e.g., a Chief ExecutiveOfficer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President, or Treasurer); or… any other individual who regularly performs similar functions.
No. However, if you open a new account, or make certain changes to your existing account (like changes of signers, officers or owners or significant changes in activity), then the new information will be required.