Effective May 11, 2018, all non-exempt new commercial customers of First Commerce Bank will be required, due to a regulatory requirement, to provide us with certain information on its Beneficial Owners, Controlling Person and Certifying Person.
This information must be provided on First Commerce Bank’s Beneficial Ownership Form before a new account can be opened or a new service can be established. Failure to complete this form when requested may result in the exiting/closing of your First Commerce Bank banking relationship.
To help the government fight financial crime, federal regulation requires certain financial institutions to obtain, verify, and record information about the beneficial owners of legal entity customers. Legal entities can be abused to disguise involvement in terrorist financing, money laundering, tax evasion, corruption, fraud, and other financial crimes. Requiring the disclosure of key individuals who ultimately own or control a legal entity (i.e., the beneficial owners) helps law enforcement investigate and prosecute these crimes.
This form must be completed and signed by the person authorized to open a new account on behalf of a legal entity (the Certifying Person*) with any of the following U.S. financial institutions:
For the purposes of this form, a legal entity includes a corporation, limited liability company, or other entity that is created by a filing of a public document with a Secretary of State or similar office, a general partnership, and any similar business entity formed in the United States or a foreign country. Legal entity does not include sole proprietorships, unincorporated associations, or natural persons opening accounts on their own behalf.
This form requires you to provide the name, primary residence address, date of birth and Social Security Number (as applicable) as well as the name of the issuer and number of the driver’s license or passport for the following individuals:
Beneficial Owner: Each individual, if any, who owns, directly or indirectly, either 25 percent or more, (e.g., each natural person that owns 25 percent or more) depending on bank instruction
Controlling Person: An individual with significant responsibility for managing the legal entity customer (e.g., a Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President, or Treasurer)
*The Certifying Person, by signing the form will attest to the completeness and accuracy of the populated information. The Certifying Person will also be required to provide on the form his/her full name, title and date of birth. Other information may be requested as part of the bank’s standard account opening/maintenance processes.
Business clients who fall into one of the categories below are generally exempt from these requirements. However, the Certifying Person may still be required to sign the beneficial owner form to attest to the exemption.
For more information related to this new regulatory requirement, you may contact your banking representative or refer to the following:
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