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Beneficial Ownership

Overview


In May 2016, the U.S. government passed a 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 legal entity customer opening or maintaining an account.

In compliance with this new regulation, The Friendship State Bank will collect beneficial ownership information from legal entity customers on or near May 11, 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 a Friendship State Bank client. This information will also be collected for existing legal entity customers who establish or maintain accounts once this new regulation is implemented at The Friendship State Bank on or near May 11, 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 (example: Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President or Treasurer).
  • The Friendship State Bank will collect information regarding the ultimate beneficial owner(s) and controlling person of legal entities whether or not they have a personal relationship with the financial institution.
 

Beneficial Ownership Information Report Filing Dates

FinCen will begin accepting beneficial ownership information reports from reporting companies that are not exempt on January 1, 2024, the effective date of the reporting requirement. 

Existing reporting companies

Created or registered to do business in the United States before January 1, 2024.
Reports due by January 1, 2025.

Updated Reports:
Required when there is a change to previously reported information about the reporting company itself or its beneficial owners. 
Updated reports due within 30 calendar days after a change occurs.


Created or registered to do business in the United States on or after January 1, 2024

Reports due within 30 calendar days of receiving actual or public notice that the creation or registration of the reporting company is effective. 

Corrected Reports:
Required when previously reported information was inaccurate when filed. 
Corrected reports due within 30 calendar days after the reporting company becomes aware or has reason to know of an inaccuracy. 

We appreciate your business and are committed to providing you with service you can Rely On for years to come.

Frequently Asked Questions:  Click Here for FAQ

Beneficial Ownership Reporting:  Click Here for Key Questions

For more information about beneficial ownership and reporting requirements: Visit the FINCEN website at https://fincen.gov/boi