Beneficial Ownership

Overview

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

In compliance with this new regulation, CIBM Bank will collect beneficial ownership information from legal entity customers starting in May of 2018. This means that any time an account is opened, renewed, 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 must be collected whether or not the person identified is a CIBM Bank client. This information will also be collected for existing legal entity customers who establish, renew, or maintain accounts once this new regulation is implemented at CIBM Bank in May of 2018.

All Customer information CIBM Bank collects is handled with the confidence in our confidentiality you have come to expect from CIBM Bank. As with all customer information, beneficial owners’ information will also be handled with respect and confidentiality.

What you need to know about Beneficial Ownership

  • The new regulation impacts all legal entities outlined in the regulation that open, renew or maintain 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 (e.g., Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President or Treasurer).
  • CIBM Bank will collect information regarding the ultimate beneficial owner(s) and control person of legal entities whether or not they have a personal relationship with us.

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

Frequently Asked Questions

The beneficial ownership regulation is a federal law requiring all financial institutions to identify and verify the identity of the beneficial owners of legal entity customers as well as a controlling person of the legal entity anytime an account is opened or maintained. The regulation is aimed at making financial institutions safer for their customers and protecting the country’s financial system.

CIBM Bank, as well as all other financial institutions in the U.S., will be required to collect beneficial ownership information. The U.S. government implemented the new beneficial ownership regulation to help fight financial crimes. CIBM Bank is doing its part in upholding the new regulation to protect the financial system. Compliance with regulations has always been of utmost importance to CIBM Bank, and the new beneficial ownership regulation will be treated with the same level of importance.

No. All financial institutions are required to comply with the new beneficial ownership regulation and will be collecting this beneficial ownership information from applicable customers.

The U.S. government regulation defines “beneficial ownership” as being made up of two roles: (1) those that have an ownership interest in a legal entity and (2) those that control a legal entity.

For those people who have an ownership interest in the legal entity, CIBM Bank is required to identify and collect personal information on anyone that meets or exceeds the following ownership thresholds:

Principal Beneficial Owners:

A natural person who owns – either directly or indirectly 25 percent or more of the equity interests of a legal entity.

Control Person

A person with significant managerial control or influence over a legal entity customer (e.g., Chief Executive Officer, Chief Financial Officer, Managing Member, General Partner, etc.)

For every legal entity client subject to beneficial ownership, you must identify one control person.

NOTE: It is possible that the control person may also be an ultimate beneficial owner.

There are a few exceptions to the collection of beneficial ownership information. It is not required to be collected for government agencies, publicly traded companies, sole proprietorships, or voluntary unincorporated associations (i.e., youth sports leagues or Scout troops).
Indirect ownership means your legal entity may be owned by one or more legal entities. We are required to obtain information on the individual persons behind those layered entities who ultimately have the equivalent of 25 percent or more ownership of your legal entity.
Yes. The certification will be marked indicating there are no individuals with beneficial ownership and the section indicating the individual with significant management responsibility will be completed.
The change should not impact your existing accounts. However, please be aware that your CIBM Bank representative may reach out for beneficial ownership information upon renewal or to update your account file, ensuring necessary compliance for any future financial requests.
For each person named on the certification, we are required to obtain their legal name, physical address, date of birth, and social security number (SSN). If they are not a U.S. citizen, then a passport number may be provided in lieu of the SSN. Additionally, we will need a copy of a government issued ID, like a driver’s license or passport, for verification of each named individual.
Once CIBM Bank has obtained a beneficial ownership certification from your legal entity, we may ask to you confirm the information when you renew your account, open additional new accounts or conduct higher risk services. 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.
Yes. Regardless of customer status, information about the ultimate beneficial owners and control person must be provided in order to comply with the regulation.
CIBM Bank will maintain beneficial ownership information in its system of record. We maintain strict privacy policies and procedures. Any client information, including beneficial ownership information, will not be shared.
No. This information will not be used for marketing or prospecting purposes.
Beneficial ownership information will be collected using CIBM Bank documents and should be returned to your CIBM Bank representative.
Yes. If you are more comfortable providing information in person, please reach out to your CIBM Bank representative directly.
No. The Beneficial Ownership regulation only applies to applicable legal entity accounts.