Beneficial Ownership Certification – current ownership, or the soon-to-be ownership?


A legal entity currently owned by a husband and soon-to-be ex-wife wants a refinance loan for the husband to buy out the ex-wife’s interest in the legal entity.  Should the Beneficial Ownership Certification be completed according to the current ownership, or the soon-to-be ownership?  In other words, 50/50 ownership or 100% Husband?


The certification should reflect the current ownership structure – 50/50 ownership by the husband and soon-to-be ex-wife.  Then, when the husband opens new accounts under the legal entity after the buyout and/or you become aware of the change in beneficial ownership (i.e. a triggering event), you will obtain/update the beneficial owner information for the legal entity’s customer profile.

Join us for the BSA/AML Annual Overview. We will answer all the questions submitted during the live webinar, in writing.


Want more BSA Resources? See our FREE BSA TOOLS!

Share This