Compliance Alliance Question of the Week

​Question:
If a customer completes a Certification of Beneficial Owners form for a DDA account and opens a Loan on the same day, may one form be used or should we have a form completed for each account?
                                                                      
Answer:
You may use one form in this case since you have obtained a certification form--as long as the information is accurate and up-to-date (assuming yes since same day).
https://www.fincen.gov/sites/default/files/2018-04/FinCEN_Guidance_CDD_FAQ_FINAL_508_2.pdf
 
            "If a legal entity customer opens multiple accounts at a covered financial institution
            (whether or not simultaneously), must the financial institution identify and verify
            the customer’s beneficial ownership for each account?
 
            A. Generally, covered financial institutions must identify and verify the legal entity
           customer’s beneficial ownership information for each new account opening,
           regardless of the number of accounts opened or over a specific period of time.
           However, an institution that has already obtained a Certification Form (or its
           equivalent) for the beneficial owner(s) of the legal entity customer may rely on
          that information to fulfill the beneficial ownership requirement for subsequent
           accounts, provided the customer certifies or confirms (verbally or in writing) that
           such information is up-to-date and accurate at the time each subsequent account
           is opened and the financial institution has no knowledge of facts that would
           reasonably call into question the reliability of such information. The institution
           would also need to maintain a record of such certification or confirmation,
           including for both verbal and written confirmations by the customer."