Beneficial Ownership Information FAQ

What is Beneficial Ownership and why do we need to know who they are?

To help the government fight financial crime, federal regulation now requires us to obtain, verify, and record information about the beneficial owners of legal entity customers. Legal entities can be abused to disguise involvement in terrorist financing, money laundering, tax evasion, corruption, fraud, and other financial crimes. Requiring the disclosure of key individuals (beneficial owners) who own and/or control a legal entity helps law enforcement investigate and prosecute these crimes.

Who is required to provide this information?

Legal entities defined as a corporation, limited liability company, general partnership, and any other entity that is created by filing a public document with a Secretary of State or similar office are required to provide beneficial ownership information

A beneficial owner is each individual, if any, who directly or indirectly owns 25 percent or more of the equity interests of a legal entity customer; and/or an individual with significant responsibility to control, manage, or direct a legal entity (i.e. an executive officer, senior manager, or other individual who regularly performs similar functions).

Who is exempt from providing this information?

Excluded legal entities include Sole Proprietorships, financial institutions regulated by a Federal functional regulator or a bank regulated by a State bank regulator and publicly traded companies.

For a complete list of excluded legal entities, visit the FinCen FAQ Site:

https://www.fincen.gov/sites/default/files/2018-04/FinCEN_Guidance_CDD_FAQ_FINAL_508_2.pdf

What information do I have to provide?

Beneficial owners of the business and one person with significant managing control must be identified. The required information includes:

• Name

• Address

• Date of Birth

• Social Security Number (or Passport Number in case of foreign persons)

• Significant Managing control

Where can I get more information?

For more information, visit the FinCen FAQ site hosted by the Department of theTreasury:

https://www.fincen.gov/sites/default/files/2018-04/FinCEN_Guidance_CDD_FAQ_FINAL_508_2.pdf

NOTE: The information provided is for validation or consumer verification only and will not affect personal credit or imply liability.