Beginning May 11, 2018, new provisions of the Bank Secrecy Act require that all financial institutions further enhance their efforts to assist the government’s fight against crimes to evade financial requirements that address terrorism and other national security threats. As part of these enhanced efforts, we will be required to collect certain information about the owners of your organization before an account is opened.

The Certification of Beneficial Owner(s) Form is provided for your convenience – this form can be downloaded and printed. Completed forms require the signature of the individual providing the information. This form cannot be digitally signed.

The completed form should be provided to the Bank by the individual who will be opening the business account, in addition to all other business identity documents (see the FAQs below).

This form must be completed before, or at account opening.

 

Frequently Asked Questions

What additional information do I have to provide before an account can be opened?

Each time an account is opened for a Legal Entity, the Bank Secrecy Act will require us to ask you for specific identifying information: name, address, date of birth, social security number, as well as acceptable identification documentation, usually a driver’s license or passport, for those who meet the qualifications below:

  • EACH individual (natural person) who has 25% or more Beneficial Ownership in the Legal Entity; and
  • ONE individual who has Significant Managerial Control of the Legal Entity.

If you are opening a business account on behalf of a Legal Entity, you will be required to provide acceptable identification and to certify that this information is true and accurate to the best of your knowledge.

What if no one owns 25% or more of the organization?

You will still need to provide the information of one person who has significant managerial control of the organization. Examples, although not all inclusive, are a President, CEO, CFO, COO, Managing Member or Controller.

What if an entity or entities own the organization?

We will be required to verify and identify each individual (natural person) of the entity that has a 25% or more ownership interest in the organization opening the account.

What is a Beneficial Ownership Certification Form?

This form will be completed at the time a new business account is opened for a legal entity. The form includes identity information about your organization’s beneficial owners that have a 25% ownership interest, identity information about one individual with managerial control and a signature of the person providing and certifying this information.

Does an owner of my company need to also be a signer on the account?

No. A beneficial owner can but is not required to be an authorized signer on the account.

What if an owner does not have a social security number?

If an owner does not have a social security number, they may provide a passport number or similar information.

How many times will I be asked to provide this information?

Each time a business account is opened for a covered Legal Entity, or certain maintenance is performed such as a title change or an authorized signer change, you will be asked to provide this additional information, even if this has been provided previously.

Will you share this information outside of the bank?

The Bank will only use this information to comply with the Bank Secrecy Act.

Does this impact consumer accounts?

All new consumer accounts will require your name, address, date of birth and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying documents; however, you will not be required to complete a Beneficial Ownership Certificate.