Beginning May 11, 2018, Federal Regulations will require all banks to obtain specific documentation of business owners. We are now required to obtain the name, address, date of birth, social security number, and a copy of an identifying document for each individual owning 25% or more of a business. The purpose of this Federal Regulation is to increase transparency regarding the ownership of legal entities. This is information that is not currently collected by the Secretary of State, at the time a legal entity is formed.

Financial institutions are required to obtain specific information each time a legal entity opens a new account, loan, certificate of deposit (CD), or safe deposit box. In an effort to make this Federal Regulation as convenient as possible for our customers, we have provided information below, which will explain what you need to provide when opening a new account, loan certificate of deposit (CD) or safe deposit box, and also if your business entity type is exempt from the regulation.

WHAT DO YOU NEED TO BRING WITH YOU WHEN OPENING A NEW ACCOUNT, LOAN, CD OR SAFE DEPOSIT BOX?
  1. Fill out the form provided on this page (the button labeled “Beneficial Ownership Form” )and bring it with you when opening a new account, loan, certificate of deposit (CD), or safe deposit box. Beneficial owners are defined as any person with 25% or greater ownership stake in a legal entity. There may be up to 4 beneficial owners listed. Business owners with less than 25% ownership do not need to be listed. If there are no beneficial owners, check the box at the bottom of page 2 on the form.
  2. Provide information regarding the individual with significant responsibility for managing the legal entity. Complete the section on page 3 of the form regarding an executive officer or senior manager (CEO, CFO, COO, Managing Member, General Partner, President, Vice President, Treasurer).
  3. Provide a copy of a valid and unexpired government issued Photo ID for each beneficial owner and the managing member.
IS MY LEGAL ENTITY TYPE AFFECTED BY THE BENEFICIAL OWNERSHIP REGULATION?

The following Legal Entity types are subject to the Beneficial Ownership Regulation:

  • General Partnerships
  • Limited Partnerships
  • Corporations
  • Limited Liability Partnerships
  • Limited Liability Companies
  • Corporate Trusts

The following Legal Entity types are EXEMPT from the Beneficial Ownership Regulation:

  • Sole Proprietorships
  • Public Funds
  • Individuals
  • Non-Corporate Trusts
  • Estate Accounts
  • Government-City and County
  • Public Schools
  • Publicly Traded Entities
  • Brokered Funds Accounts
  • Financial Institutions regulated by Federal or State regulators
  • Investment companies
  • Insurance Companies that are state regulated

Please contact your local office with any questions or concerns or you may contact our Bank Secrecy Act Officer, Kevin Banasik via email kevin.banasik@csbiowa.com, or by phone 319-447-2551.