Beneficial Ownership

Each time an account is opened for a covered legal entity, we are required to ask you for identifying information (name, address, date of birth, social security number, as well as identification documents) for each individual that has beneficial ownership (25% or more) and one individual that has significant managerial control of the legal entity.

If you are opening an account on behalf of a legal entity, you will be required to provide the appropriate documentation and to certify that this information is true and accurate to the best of your knowledge.

While we understand the information requested is personal and sensitive, we need to obtain this information in order to comply with the law. As always, we will treat all information collected with the utmost care. All information will be stored securely and handled with the same standard of privacy that we have always maintained.

This new requirement is in response to the Corporate Transparency Act, enacted in 2021. This law created a beneficial ownership information reporting requirement as part of the U.S. government’s efforts to make it harder for bad actors to hide or benefit from their ill-gotten gains through shell companies or other opaque ownership structures. A beneficial owner is any individual who, directly or indirectly, owns or controls at least 25% of the company.

Essentially, all U.S. companies (including LLCs, corporations, and partnerships) will need to identify and report their beneficial owners to the government.

There are 23 entity types exempt from the beneficial ownership information reporting requirements. These entities include publicly traded companies, nonprofits, and certain large operating companies. The list of entity types can be found on FinCEN's website.

Reporting companies will have to report beneficial ownership information electronically through FinCEN's website. The system will provide the filer with a confirmation of receipt once a completed report is filed with FinCEN. There are no fees or additional cost associated with the registration process.

To comply with current beneficial ownership rules under the Bank Secrecy Act, financial institutions are required to continue obtaining current beneficial ownership information.

Instructions on how banks will complete validation of your registration with FinCEN have not yet been published. As soon as information is available, we will update this section to reflect our process.