Beneficial Ownership Requirements

Important information about opening a new business account or loan

Effective March 31, 2018, we will implement new rules that 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.  

A Beneficial Owner is:

  • Each individual who owns 25% or more of the company
  • One individual who has significant managerial responsibility for the company

Why the change?

New rules under the Bank Secrecy Act require financial institutions to identify and verify business owners before a new account may be established. This rule applies to accounts such as checking, savings, Certificates of Deposit, safe deposit boxes and loans. Each time a business account is opened we are required to ask for identifying information for each individual who has beneficial ownership (20% or more) and one individual who has significant managerial control of the business.

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

In order to make this process as efficient as possible, you will be required to provide the following:

Information you will need to provide:

  • Name
  • Address (Personal or Business)
  • Date of Birth
  • Social Security Number or Tax Identification Number

Acceptable forms of identification:

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

Why we need this information

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account.

Section 326 of the USA PATRIOT Act requires that financial institutions identify and verify the identity of the beneficial owners of all legal entity customers at the time a new account is opened. The identification and verification procedures for beneficial owners are very similar to those you currently follow as individual customers.

Businesses that are affected

The rule applies to legal-entity businesses such as a corporation, limited liability company, and general partnership, or other entity created by a filing of a public document with a Secretary of State or similar office.

Businesses exempt from the requirements 

These businesses are generally exempt:

  • Sole proprietorships
  • Trusts and estates
  • U.S. and state government entities
  • Registered insurance companies
  • Publicly-traded companies and subsidiaries
  • Charities and nonprofit entities
  • Unincorporated associations such as scout troops or youth sport leagues

Types of accounts included:

The rule applies to accounts such as checking, savings, certificates of deposit, and loans held at banks, credit unions, investment firms, and other financial services providers.

Who needs to provide information?

Each time an account is opened, we are required to ask you for identifying information as well as:

  • Each individual who owns 20% or more of the business, and
  • One individual with significant responsibility for managing the business (e.g. Chief Executive Officer, Chief Financial Officer, Partner, President, Vice President, or Treasurer.)
  • This information must be collected whether or not the individuals are bank clients.

For existing customers:

If you open a new account, renew or secure a new loan, or during additional circumstances, ownership information must be provided.


If you have any questions or need additional information, call your relationship manager or stop by your nearest branch location.

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