In response to regulations issued by the Federal Government, SF Fire Credit Union has new requirements regarding the information we must collect and maintain on certain business accounts. These regulations require all credit unions, banks, and savings associations to collect identifying information about the owners and/or persons with operational control over a legal entity (certain types of businesses or organizations). We must collect this information:
Before a business membership or a new account can be opened for that legal entity
At the time of any change to an existing account in the name of the legal entity
When the credit union believes there has been a significant change in ownership, control, or activity of the business.
What types of businesses or organizations are considered a legal entity and subject to these regulations?
Under the Beneficial Ownership rule, a legal entity is defined as:
- Limited Liability companies
- Limited Partnerships
- General Partnerships
- Statutory Trusts
- Any other entity created by filing with a state office
What’s not considered a legal entity under the regulations?
- Sole Proprietorships
- Unincorporated Associations
- Trusts which have not been filed with the state
What information do you need to provide?
If you want to open an account or make changes to an existing account for a legal entity, you or someone else will have to sign a certification that verifies the following information:
- Dates of Birth
- Identifying numbers (such as Social Security Numbers)
- Photo Identification
This information will be required for any individuals holding 25% or more of equity in the legal entity, as well as for any one person who has significant control over the organization, such as a General Manager or CEO.
How often will you be asked to certify your ownership information on an existing business membership?
The Beneficial Ownership rule requires us to have our members re-certify their ownership and controlling individual’s information under the following circumstances:
- Opening a new account, including loans and/or lines of credit
- Loan extensions or renewals
- Account maintenance/updates (address changes, etc.)
- Change in account ownership and/or signers
- Change in ownership structure of the business
- Change in beneficial ownership of the business
Will this change how you conduct business in the branches?
Daily transactions such as deposits or withdrawals will not be affected, but these new requirements mean it will usually require more time to complete changes such as those listed above. We strongly encourage you to schedule an appointment on our website. Please make sure bring all the required information with you, as we will be unable to complete these changes without completing the certification process first.
Must all the owners and the person with control over your organization be present to open a new account or make changes to an existing account?
No. We can take the required information and identifying documentation (photo ID, etc.) from one individual acting on behalf of the owners and/or controlling individuals.
Is the ownership information kept confidential?
Yes. Beneficial ownership information is considered confidential and is protected using security measures that comply with federal and state law.