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Beneficial Ownership

Attention Business Owners

Overview

In May 2016, the U.S. government passed a new regulation regarding the beneficial ownership of legal entity customers. Going forward, it will be mandatory for all financial institutions to comply with this regulation by identifying the ultimate beneficial owner(s) and a controlling person of a legal entity customer opening or maintaining an account (e.g. deposit, loan or safe deposit box).

In compliance with this new regulation, Exchange Bank will collect beneficial ownership information from legal entity customers in the second quarter of 2018. This means that any time an account is opened or maintained for a legal entity, we will request information that identifies the ultimate beneficial owner(s) and controlling person of the legal entity. The required identifying information includes name, address, date of birth, identification number, and other information that will help identify those individuals. This information will need to be collected whether or not the person identified is an Exchange Bank customer. This information will also be collected for existing legal entity customers who establish new accounts once this new regulation is implemented at  Exchange Bank in the second quarter of 2018.

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).
  • Exchange Bank will collect information regarding the ultimate beneficial owner(s) and control person of legal entities whether or not they have a personal relationship with the Bank.

Information you will need to provide

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

Examples of acceptable forms of identification

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

Resource Material

 


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