This new rule should not affect your existing accounts. However, there may be circumstances where certification must be completed in order to update your records. To combat financial crime and terrorist financing, the U.S. government has passed new regulations requiring financial institutions to collect beneficial ownership information from customers of legal entities. This regulation was adopted to create more transparency in corporate structures where the people behind the structure can be hidden, and to better protect the U.S. financial system. This new requirement obliges SVB Private to collect information about the company`s ultimate beneficial owners in order to open an account in the company`s name. An ultimate beneficial owner is the natural person(s) who exercise ultimate ownership and control over the corporate structure. If your company is owned by another company, the ultimate beneficial owners are natural persons with a stake of 25% or more in the parent company, as well as a person with significant responsibility for controlling, administering or directing the parent company. In the example below, Allan and Betty are both beneficial owners, as they are both equal trustees of ABC Family Trust, which owns more than 25% of the shares of the client company. Carl and Diane are also beneficial owners, as they both hold 25% of the indirect ownership of the client business through Company B. Keep in mind that anyone who directly or indirectly owns 25% or more of the interests in your business must be listed on the form and provide their information. In addition, a controlling person (e.g.
CEO or Director General) must be designated. SVB Private may also request to see a copy of a driver`s license or other identification document for each beneficial owner listed on this form. When running a business, it`s important to have a trusted financial partner – a team of experts who listen to you and help you make informed decisions. Whether you`re looking for expertise in financing future growth, processing payments, maximizing cash flow, or any other financial need, Old National is here to help. While we understand that the information collected may be personal in nature, it is necessary to comply with federal regulations. We protect our customers` information with all the safeguards you expect and will never disclose confidential information collected under this Policy to third parties unless required by law. If a trust directly or indirectly holds a 25% or more interest in your business and the trustee is another legal entity such as a law firm, bank or trust and there is no natural person as a co-trustee, the legal entity may be registered as a beneficial owner. The name, address and identification number of the legal entity of the agent must be provided, and SVB Private may request additional documents. However, if there are more than one trustee or co-trustee, one of whom is a natural person, the information must be provided to that person as the beneficial owner. Information of a legal person as trustee can only be provided if a natural person does not exist for the purposes of beneficial ownership. SVB Private, as well as all other financial institutions, is required to comply with this new regulation and collects beneficial ownership information by completing a certification form for all accounts opened from 9 May 2018 in the name of a company. For each company, SVB Private is required to obtain the name, address, date of birth and social security number (or passport number for foreign persons) for each person holding 25% or more of the shares and a controlling person.
This means that whenever you open an account for a company from this date, SVB Private may ask you to provide or update the name, address, date of birth and beneficial ownership identification number of the company. No, the information you provide will not be used for advertising or prospecting purposes. Yes, the information must also be collected in situations where the owners and controllers have no relationship with SVB Private. In the following example, the information must be provided for the trustee of the corporation (XYZ Trust), Carl and Diane as beneficial owners. In addition, a controlling person (e.g. CEO or Director General) must be designated. Of course. Although we ask to complete the certification form, please contact your account manager to personally complete the certification form if you wish to provide the information personally.