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Beneficial Owner FAQs

The rule defines the following as legal entity customers:

  • Corporations, including single owner S-corporations
  • Limited liability companies
  • Other entities that are created by the filing of a public document with a Secretary of State or similar office
  • General partnerships
  • Any similar entities formed under the laws of a foreign jurisdiction that open an account
  • Limited partnerships and business trusts that are created by a filing with a state office, or any other entity created in this manner as well as similar entities formed under the laws of other countries

The following are not considered legal entity customers under the new rule:

  • Sole proprietorships and most trusts
  • Unincorporated associations (small local community organizations such as Scout Troops and youth sports leagues)
  • Natural persons opening accounts on their own behalf

A beneficial owner is any individual that has ownership and/or control of the legal entity customer.

Under the rule, an individual is considered a beneficial owner if she/he directly or indirectly, through any contract, arrangement, or understanding, relationship or otherwise, has an individual equity interest of 25% or more of the legal entity customer.

Under the new rule, a “control” individual is a person with significant responsibility for managing the legal entity customer. This may include someone like an executive officer or senior manager (e.g. a Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President, or Treasurer).

Interra will provide the account opener with a beneficial ownership certification form that must be completed prior to account opening. The account opener attests to the accuracy of the information in the certification form.

An account opener is an individual who opens an account for a legal entity customer.

Certification information includes:

  • Name (first, middle, last) and job title of the account opener
  • Name and address of the legal entity customer (street address, city, state/province, country and zip code)
  • The information below is required for beneficial owners:
    • Name
    • Date of birth
    • Physical address
    • For U.S. Persons: Social Security Number
    • For Non-U.S. Persons: Social Security Number, passport, alien ID, other government issued ID including document number and place of issuance.

The Customer Due Diligence Requirements for Financial Institutions Final Rule can be found here: https://www.gpo.gov/fdsys/pkg/FR-2016-05-11/pdf/2016-10567.pdf

The Financial Crimes Enforcement Network (FinCEN) issued FAQs to assist in understanding the scope of the Customer Due Diligence Requirements for Financial Institutions which can be found here:
https://www.fincen.gov/resources/statutes-regulations/guidance/frequently-asked-questions-regarding-customer-due-0

 

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Beneficial Owners

What you need to open an Interra Business Account

Thank you for considering Interra Credit Union for your business membership. We appreciate the opportunity to earn your business. You may open a business account by visiting any branch location. In addition to a primary and secondary identification, below is a list of the information needed to establish your business membership: 

ID Information

Sole Proprietorship

  • EIN Certification (IRS), if applicable
  • Certificate of Assumed Business Name filed with county recorder’s office (aka: Trade Name Record, Assumed Name Certificate, or Fictitious Name Certificate.  Required if the individual is not using his/her last name as part of the business name.)
  • Primary and Secondary ID, and Social Security Number for owner and all account signers
  • Physical address of principal place of business and, if different, a mailing address
  • Sole Proprietorship Resolution – provided by Interra

Corporations (profit and not for profit, including incorporated churches)

  • EIN Certification (IRS)
  • Articles of Incorporation
  • Certificate of Assumed Business Name filed with Secretary of State (applicable if operating under a different name than the legal entity.)
  • Primary and Secondary ID, and Social Security Number for all account signers
  • Physical address of principal place of business and, if different, a mailing address
  • Corporate Resolution – provided by Interra
  • Certification of Beneficial Owners – provided by Interra

Partnership – General Partnership, Limited Partnership (LP), Limited Liability Partnership (LLP)

  • EIN Certification (IRS)
  • Partnership Agreement, if available
  • Certificate of LP or LLP (Secretary of State – required if partnership agreement doesn’t exist)
  • Certificate of Assumed Business Name (applicable if operating under a different name than the legal entity.)
    • General Partnership – filed with county recorder’s office
    • LP and LLP – filed with Secretary of State
  • Primary and Secondary ID and Social Security Number for all account signers
  • Physical address of principal place of business and, if different, a mailing address
  • Partnership Resolution – provided by Interra
  • Certification of Beneficial Owners – provided by Interra

Limited Liability Company (LLC)

  • EIN Certification (IRS)
  • Articles of Organization (Secretary of State)
  • Certificate of Assumed Business Name filed with Secretary of State (applicable if operating under a different name than the legal entity.)
  • Primary and Secondary ID and Social Security Number for all account signers
  • Physical address of principal place of business and, if different, a mailing address
  • LLC Resolution – provided by Interra
  • Certification of Beneficial Owners – provided by Interra

Unincorporated Association, Religious, Charitable, Educational or Tax Exempt Organization   

  • EIN Certification (IRS) (or) Letter from organization authorizing use of EIN
  • Bylaws (or) Minutes reflecting elected authorized signers (or) official letter signed by the President of the organization authorizing the establishment of the account and respective signers.
  • Certificate of Assumed Business Name filed with county recorder’s office (applicable if operating under a different name than the legal entity.)
  • Primary and Secondary ID and Social Security Number for all account signers
  • Physical address of principal place of business and, if different, a mailing address
  • Unincorporated Club/Organization/Association Resolution – provided by Interra
  • Certificate of Beneficial Ownership – provided by Interra, if applicable (i.e. organization is legal entity as defined by FinCEN rule 31 CFR 1010.230 for beneficial ownership)

*If opening a church account, other than a club or group, please provide documentation as listed above for a Corporation.

Beneficial Ownership

What is the beneficial ownership regulation and why does it matter?
The U.S. Department of Treasury recently issued a final rule titled “Customer Due Diligence Requirements for Financial Institutions” (31 CFR 1010.230) that creates new due diligence obligations for credit unions and other financial institutions. All financial institutions are now required to collect and verify the identities of certain individuals who own or control legal entity customers, including corporations, limited liability companies (“LLCs”), partnerships, and other legal entities. Individuals who own or control legal entity customers are considered “beneficial owners” of that entity. The regulation is aimed at making financial institutions safer for their customers and protecting the country’s financial system.

What is required?
The regulation requires Interra to gather the following information from beneficial owners of its new and existing legal entity customers:

  • Name,
  • Date of birth,
  • Current physical residential address or business address, and
  • Social Security Number (or other government issued identification number for non-U.S. citizens without a SSN).

Most U.S. publicly traded entities, regulated entities, and government entities will be excluded from these requirements.

How will the new requirement impact me?
An Interra representative may ask to review the following documentation:

  • A document verifying your identity and date of birth, such as a driver’s license or passport. A copy of the identification document may also be requested.
  • A document verifying your current address, if not listed on the document.

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.  We appreciate your business and are committed to providing you with extraordinary service for years to come.

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