Beneficial Ownership

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.

United Bank of Union, 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.

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.

The U.S. government regulation defines “beneficial ownership" as being made up of two prongs (1) Ownership Prong and (2) Control Prong.

Ownership Prong

• A beneficial owner is an individual, if any, who, directly or indirectly, owns 25% or more of the equity interest of a legal entity customer.

Control Prong

• A single individual with significant responsibility to control, manage, or direct a legal entity customer, including an executive officer or senior manager (i.e. Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President, or Treasurer), or any other individual who regularly performs similar functions.

For every legal entity client subject to beneficial ownership, you must identify one control person.

NOTE: It is possible that the control prong person may also be in the ownership prong.

The change should not impact your existing accounts. However, please be aware that your United Bank of Union representative may reach out for beneficial ownership information if the account is modified.

Yes. Regardless of customer status, information about the ultimate beneficial owners and control person must be provided in order to comply with the regulation.

The required identifying information includes name, address, date of birth, social security number, and other information that will help identity those individuals.

Acceptable forms of identification:

• Driver’s License
• State-issued Identification Card
• Passport
• Alien Identification Card

United Bank of Union will request a copy of one identification form. A photocopy will be acceptable.

• Corporations
  • For Profit Corporations- The entire form filled out
  • Not for Profit Corporations- Only have to fill the control prong out
    • Examples of Not for Profit Corporations:
      • Girl Scout Accounts
      • Church Accounts
    • Limited Liability Companies
    • Limited Liability Partnerships
    • Limited Liability Limited Partnerships
    • Limited Partnerships
    • General Partnerships
    • Business Trusts
    • Any other entity created by filing with a state office
    • Any similar entities formed under the laws of non-U.S. jurisdiction

• Natural persons
• Sole proprietorships
• Unincorporated associations
• S. and state government entities
• Trusts, other than statutory trusts created by a filing with a state office
• Federal or state regulated financial institutions (e.g federally regulated banks, brokers or dealers in securities, mutual funds, futures commission merchants, and introducing brokers in commodities
• Bank and savings and loan holding companies
• State-regulated insurance companies
• Publicly held companies listed on the New York, American, or NASDAQ stock exchanges.
• Registered investment advisers and investment companies

The rule applies to accounts such as checking, savings, certificate of deposits, safe deposit boxes, and loans.

Loans:

This will include any new, renewal or modification of loans.