Beneficial Owner FAQs

The new CDD Rule amends existing regulations in order to clarify and strengthen customer identification requirements for financial institutions. These regulations are aimed at making financial institutions safer for their customers while helping prevent financial crimes such as money laundering, terrorist financing, tax evasion, and fraud.

No. All financial institutions within the United States are required to collect beneficial ownership information from applicable customers.

A legal entity is a corporation, limited liability company, a general or limited partnership, or business trust created by a filing with a state office. This also includes a similar entity formed under the laws of another country.

Beneficial ownership consists of beneficial owner(s) and a controller:

• A beneficial owner is any individual owning 25% or more of the equity interests of a legal entity
• A controller is an individual with significant responsibility to control, manage, or direct a legal entity (ex. Chief Executive Officer, Chief Financial Officer, Managing Member, General Partner, Authorized Signer, etc.)

We are required to obtain the following personal information for all beneficial owners and control persons: legal name, physical address, date of birth, and identification number (SSN or passport number for non-U.S. citizens). For verification purposes, we’ll need to obtain a copy of a government-issued ID such as a driver’s license or passport. While we understand the information required is personal and sensitive, it is required that we obtain it in order to comply with the law.

Any legal entity customer that opens a new account, or renews or extends an existing loan on or after May 11, 2018 will be required to provide identifying information about the beneficial owners or control person.

The Certification of Beneficial Owner(s) form certifies the beneficial owners and control person for business customers operating as a legal entity. This form must be completed by the beneficial owner, controlling individual, or authorized account signer. The person who completes the certification will sign and attest that the information provided is accurate to the best of his or her knowledge.

Yes. You would simply mark the box indicating there are no individuals with beneficial ownership of 25% of more and complete the section for the controlling individual with the significant management responsibility. A controlling individual may include: Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President, Treasurer, or any other person with significant responsibility to control, manage, or direct the legal entity.

Once Brenix Credit Union Bank has obtained a beneficial ownership certification for your legal entity, we may ask that you confirm the information when you open additional new accounts or renew or extend a loan. Please let us know if there is a change in ownership or control of your company so we can obtain an up-to-date certification that reflects accurate information.

This is a government regulatory requirement; thus, we strongly suggest you to complete the Certification form to ensure uninterrupted service on your account.

We are required to maintain this information as part of our records associated with your legal entity. We treat this information with the same level of confidentiality and security as we do all our customer information. Any customer information, including ownership information, will not be shared or used for marketing purposes.

If you have any questions, please do not hesitate to contact your Relationship Manager or call our Customer Service Center at 888.895.5650, Monday – Friday, 6:00 am to 7:00 pm PT, and Saturday, 9:00 am to 5:00 pm, PT.