Beneficial Ownership
what it means for you

overview

As of May 11, 2018, all banks are subject to new rules under the USA PATRIOT Act to help support our government's fight against terrorism and other national security threats. All non-exempt business customers will be required to provide Security National Bank with certain information on its Beneficial Owners and/or an individual with Significant Managerial Control (i.e. Control Person).

What is the Certification of Beneficial Owners Form?

The Beneficial Ownership Certification Form, linked below, is a form Security National Bank is collecting from legal entity customers regarding their ultimate Beneficial Owners and Control Person. The individual completing the form is attesting that the information provided is accurate to the best of their knowledge. The form must be provided before a new account can be opened or a new service can be established.

CERTIFICATION OF BENEFICIAL OWNERS FORM

Who must complete the Certification Beneficial Owners Form?

This form must be completed and signed by the individual opening a new account on behalf of a legal entity. The information requested on this form is required to be collected by such U.S. financial institutions such as a bank or credit union, a broker or dealer in securities, a mutual fund, futures commission merchant, or an introducing broker in commodities.

For the purposes of this form, a legal entity includes:

  • A corporation, limited liability company, or other entity 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 proprietorships, unincorporated associations, or natural persons opening accounts on their own behalf.

What information must I provide on the Certification  of Beneficial Owners Form?

This form requires you to provide the following:

  • Name
  • Primary residence address
  • Date of birth
  • Social Security Number (as applicable)

For the following individuals:

  • Beneficial Owner: Each individual, if any, who owns, directly or indirectly, 25 percent or more of the equity interests of the legal entity AND

  • Control Person: An individual with significant responsibility for managing the legal entity customer (e.g., a Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President, or Treasurer)
    • If these individuals are not present at account opening, a photocopy of their driver's license or other acceptable form of identification must also be provided.
    • The number of individuals satisfying this definition of beneficial owner may vary.
    • Regardless of the number of individuals identified as beneficial owners, you must provide the identifying information of one individual identified as the Controlling Person.
    • It is possible that in some circumstances the same individual might be identified as both Beneficial Owner and Control Person. For example, you may have the Chief Executive Officer of Widgets, Inc. who also holds a 30% equity interest.

We will also request to see an acceptable form of identification (e.g. Driver’s License, State-issued Identification Card, Passport) for each Beneficial Owner. Photocopies are acceptable. Other information may be requested as part of Security National Bank’s standard account opening processes.

Other FAQs:

 


For more information related to this new regulatory requirement, you may contact your banking representative or refer to the following:

 Federal Register

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