Effective May 11, 2018, new rules under the Bank Secrecy Act will aid the government in the fight against crimes to evade financial measures designed to combat terrorism and other national security threats.
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.
What you need to know about Beneficial Ownership
The new regulation impacts all legal entities opening or maintaining accounts at any financial institution. Legal entities will need to identify and attest to all ultimate beneficial owner(s) that meet specific requirements as well as a controlling person (e.g. Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President or Treasurer).
United Community Bank is required collect information regarding the ultimate beneficial owner(s) and control person of legal entities whether or not they have a current relationship with us.
If you would like to get started or have been asked by us to update your Beneficial Ownership Information, click the button below to be brought to our Beneficial Ownership Form. The completed form and a copy of a drivers's license or other identifying documentation for each individual listed on the form can be brought with you to any one of our locations or can submit electronically via our Secure Portal. Please do not email this sensitive information directly to an employee of United Community Bank.
We will also require a copy of primary identification on each beneficial owner and the control person.
Frequently Asked Questions
What is the beneficial ownership regulation and why does it matter?
The beneficial ownership regulation is a federal law requiring all financial institutions to identify and verify the identity of the beneficial owners of legal entity customers as well as a controlling person of the legal entity anytime an account is opened or maintained. The regulation is aimed at making financial institutions safer for their customers and protecting the country’s financial system.
Why has United Community Bank been asked to collect this information?
United Community Bank, as well as all other financial institutions in the U.S., will be required to collect beneficial ownership information. The U.S. government implemented the new beneficial ownership regulation to help fight financial crimes. United Community Bank is doing its part in upholding the new regulation to protect the financial system. Compliance with regulations has always been of utmost importance to First Interstate, and the new beneficial ownership regulation will be treated with the same level of importance.
Is United Community Bank the only bank that is required to collect beneficial ownership information?
No. All financial institutions are required to comply with the new beneficial ownership regulation and will be collecting this beneficial ownership information from applicable customers.
What information does a Legal Entity need to provide?
The beneficial owner final rule expands upon the 2003 Customer Identification Program requirements which required the collection of and verification of customer name, date of birth, address and tax identification number.
The extension includes the identification of those natural persons defined as beneficial owners of a legal entity.
Beneficial owners can be defined in two ways:
- Ownership prong: Each individual who, directly or indirectly, owns 25% or more of the equity interests of the legal entity customer.
- Control prong: One individual with significant responsibility to control, manage or direct the legal entity customer, and their corresponding title (e.g. Chief Executive Officer, Chief Operating Officer, President, Vice President, and Managing Member).
Some exclusions may apply.
What documentation is collected on an identified Beneficial Owner?
Beneficial ownership information will be collected at account opening for new accounts and anytime a beneficial owner of the legal entity changes.
Information required for the Ownership and Control Prong individuals include:
- Full Name
- Date of birth
- Address (residential or business street address, no P.O. Boxes)
- Social security number or ITIN (for U.S. persons or permanent resident aliens)
- In lieu of SSN or ITIN, primary identification number can be used (for non U.S. persons)
- Percentage of ownership (ownership prong)
- Title (control prong)
Verification of unexpired, government-issued identification bearing a photograph, evidencing nationality or residence.
The natural person opening the account on behalf of the legal entity will be required to be an authorized signer and sign a certification form attesting that the information provided on beneficial ownership is complete and correct.
How will the change impact my existing accounts?
The change should not impact your existing accounts. However, please be aware that your United Community Bank representative may reach out for beneficial ownership information to update your account file, ensuring necessary compliance for any future financial requests.
What if the people who have been identified as beneficial owners or control persons are not clients of United Community Bank? Do I still need to provide their personal information to United Community Bank?
Yes. Regardless of customer status, information about the ultimate beneficial owners and control person must be provided in order to comply with the regulation.
My United Community Banker has asked me for a Certification of Beneficial Ownership. What is this and why is it necessary?
The Certification of Beneficial Ownership is a legally required form that United Community Bank must collect from legal entity customers regarding their ultimate beneficial owners and the control person. By completing the form, you are attesting that the information provided is accurate to the best of your knowledge.
Where will beneficial ownership data be stored?
United Community Bank will maintain beneficial ownership information in its system of record. We maintain strict privacy policies and procedures. Any client information, including beneficial ownership information, will not be shared.
Will the information I provide for beneficial ownership be used for marketing to prospects that do not already have a relationship with United Community Bank?
No. This information will not be used for marketing or prospecting purposes.
How do I get beneficial ownership information back to my United Community Banker?
Beneficial ownership information will be collected using internal bank documents and should be returned to your United Community Bank representative. Forms are also available online and can be submitted electronically using our secure portal. For more information, click here for our Secure Portal.
Given the sensitive nature of the information that is being provided for beneficial ownership, can I provide the details directly to my United Community Bank representative?
Yes. If you are more comfortable providing information in person, please reach out to your United Community Bank representative directly.
I also have personal accounts with United Community Bank. Will United Community Bank also collect beneficial ownership information for my personal accounts?
No, the beneficial ownership rule does not apply to individual.