Beneficial Ownership

Overview

In May 2016, the U.S. Government passed a new regulation regarding the beneficial ownership of legal entity customers. Beginning, May 11, 2018, this regulation will become effective and 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 order to comply with this new regulation, Republic Bank of Chicago 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, the Bank is required to request information that identifies the ultimate beneficial owner(s) and a controlling person of that legal entity.

The required information includes:

  • Full name
  • Address
  • Date of Birth
  • Taxpayer Identification Number
  • and other information that will help identify these individuals

This information will need to be collected whether or not the person identified is a Republic Bank of Chicago customer.

While we understand that 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.

What you need to know about Beneficial Ownership

  • The NEW regulation affects legal entities opening or maintaining accounts at ANY financial institution.
  • Legal entities will need to identify and attest to all beneficial owner(s) that meet specific requirements as well as a controlling person (e.g. CEO, CFO, COO, Managing Member, General Partner, President, Vice President, etc.)
  • Republic Bank of Chicago will collect information regarding the ultimate beneficial owner(s) and controlling person of legal entities whether or not they have a personal relationship with the Bank.

For additional information, please see the FAQs below.

Frequently Asked Questions:

What is the beneficial ownership regulation and why does it matter?

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.

What constitutes beneficial ownership?

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, Republic Bank of Chicago is required to identify and collect personal information on anyone that meets or exceeds the following thresholds:

  • Ultimate Beneficial Owners
    A natural person having 25% 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 person (e.g. CEO, CFO, COO, Managing Member, General Partner, President, Vice President, 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.

Why has Republic Bank of Chicago been asked to collect this information?

Republic Bank of Chicago, 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. Republic Bank of Chicago is doing its part in upholding the new regulation to protect the financial system. Compliance with regulations has always been of utmost importance to Republic Bank of Chicago, and the new beneficial ownership regulation will be treated with the same level of importance.

Is Republic Bank of Chicago the only bank that is required to collect beneficial ownership information?

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.

What is “Certification of Beneficial Ownership” and why is it necessary?

The Certification of Beneficial Ownership is a legally required form that Republic Bank of Chicago 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.

Copyright © 2018 Republic Bank of Chicago. All rights reserved.

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