Pub. 9 2018 Issue 1

Spring 2018 21 West Virginia Banker Step 3: Who Do I Get the Owner- ship Information From? The beneficial ownership information – who the owners are, how much they own, who is in charge - is going to be given to you by the person opening the account. Does that mean a beneficial owner has to open the account? No - the person has been given the right to open the account by the company can give you this information. That means that the person opening the account may very well not be one of the 5 people you’re collecting the beneficial ownership information on. Step 4: What Do I Have to Collect? What you’re actually going to be col- lecting on each individual is really similar to CIP information: name and title of the individual, name and address of the business, date of birth and Social Security Numbers for US citizens and Passport Numbers for non-citizens. One big difference is, unlike CIP, you can accept copies of those documents as verification instead of the actual ID. So that means, the person opening the account can come prepared with that information. Step 5: How Do I Collect It? There’s also a model certification form in the appendix which you can take from your customers to identify those beneficial owner individuals. It’s basically going to allow the customer to just list their up-to-four beneficial owners and the single individual who is listed as controlling the company. You can use the model form but it’s not a requirement – so if you want to take that information in some other fashion, you can do that. The person opening the account has to sign off on the information being correct regardless of how it’s collected. Step 6: When Do I Have to Collect? This information has to be collected every time a legal entity opens a new account – it’s not based on the legal en- tity being a new customer – it’s literally every time they open a new account, even if the entity has banked with the bank for 20 years. Additionally, after the rule came out, we started hearing panelists at regulator panels and different parties indicating that the beneficial ownership rules apply to renewals of CDs and loans. However, it’s also important to be aware the FDIC has also indicated that auto-renewals of CDs do not trigger Beneficial Ownership requirements. Since there have been conflicting opinions on this topic, it’s always best practice to get an interpreta- tion directly from your own regulator. So there’s the rule – similar to CIP but requires more organization information from your business customers. Compli- ance Alliance does have a full BSA/AML compliance toolkit including Beneficial Ownership tools.  “Bankers’ Bank is our go to source for correspondent banking needs. They have been providing us great, friendly service for many years .” David Hines, Senior Vice President, Community Bank of Parkersburg “Premier Bank has had a very long and rewarding relationship with the Bankers’ Bank. We have always found them to be very responsive and helpful with new projects, as well as, the daily processes. They exhibit a real desire to provide individualized service to their clients. We are happy to partner with them.” Emma Byrnside, Executive Vice President, Premier Bank, Inc. MEMBER FDIC David Fletcher, Vice President has over 25 years of experience serving the banks of West Virginia. Let his experience work for you. Email: dfletcher@bbky.com Phone: 304-389-4431 • www.bbky.com The Bankers’ Bank... The Bankers’ Bank, chartered in 1988, oŽers products and services designed specifically to help Community Banks thrive and remain competitive in their markets. The Bankers’ Bank’s friendly, experienced Correspondent Banking Professionals are ready to work for your bank. OUR SERVICES INCLUDE: • ATM Debit Card • ATM Managed Services • MoneyPass® Surcharge Free ATM Network • Loan Participations Buy/Sell, Holding Company • Lines of Credit, D&O Loans • Federal Fund Lines of Credit • Investment Safekeeping, Bond Accounting, & Trading • Credit Card Program • Asset Liability Management Reporting & Training • Clearing Settlement • Payroll, HR, ACA & DOL Solutions • Merchant Services • International Wire Transfers & Foreign Collection • Internet Banking • Mobile Banking Solutions and much more! Your Correspondent Partner Silvia Garcia Maggio serves as an Associate General Counsel for Compliance Alliance. Compliance Alliance offers a comprehensive suite of compliance management solutions. To learn how to put them to work for your bank, call (888) 353-3933, visit compliancealliance. com, or emai l info@ compliancealliance.com.