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, Marine Bank, a branch of 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 handles 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 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.
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.