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In May 2016, the U.S. government passed a new regulation regarding the beneficial ownership of legal entity customers. Beginning May 11, 2018, 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, Providence Bank & Trust will collect beneficial ownership information from legal entity customers starting on 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:
This information will need to be collected whether or not the person identified is a Providence Bank & Trust customer. This information will also be collected for existing legal entity customers who establish or maintain accounts once this new regulation is implemented at Providence Bank & Trust.
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.
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 any time 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.
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, Providence Bank & Trust is required to identify and collect personal information on anyone that meets or exceeds the following ownership thresholds:
A natural person having 25 percent or more of the equity interests of a legal entity.
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, President, Vice President, Treasurer, 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.
Providence Bank & Trust, 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. Providence Bank & Trust is doing its part in upholding the new regulation to protect the financial system. Compliance with regulations has always been of utmost importance to Providence Bank & Trust, 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 regulation is effective as of May 11, 2018.
The change should not impact your existing accounts. However, please be aware that your Providence Bank & Trust Relationship Manager or a Relationship Banker may reach out for beneficial ownership information to update your account file, ensuring necessary compliance for any future financial requests.
You will be required to provide their personal information regardless of customer status. Information about the ultimate beneficial owners and control person must be provided in order to comply with the regulation.
The required identifying information includes:
The Certification of Beneficial Ownership is a legally required form that Providence Bank & Trust must collect from legal entity customers regarding their ultimate beneficial owners and the control person. By completing the form, you are attesting that the information provided is accurate to the best of your knowledge.
Providence Bank & Trust maintains strict privacy policies and procedures. We will maintain all beneficial ownership information in the same manner as a bank customer. Any customer information, including beneficial ownership information, will not be shared.
No. This information will not be used for marketing or prospecting purposes.
No. The Beneficial Ownership regulation only applies to applicable legal entity accounts.