Beneficial Ownership

Under the Bank Secrecy Act, financial institutions are required to help the government fight financial crime by obtaining, verifying, and recording information about the beneficial owners of legal entity customers.

Each time an account is opened for a covered legal entity, we are required to ask you for identifying information (name, address, date of birth, social security number, as well as identification documents) for each individual that has beneficial ownership (25% or more) and one individual that has significant managerial control of the legal entity.

If you are opening an account on behalf of a legal entity, you will be required to provide the appropriate documentation and to certify that this information is true and accurate to the best of your knowledge.

We proudly support all efforts to protect and maintain the security of our customers and our country.

What you need to know about Beneficial Ownership

For the purposes of this regulation, a legal entity includes a corporation, limited liability company, or other entity that is created by the filing of a public document with a Secretary of State or similar office, a general partnership and any similar business entity formed in the United States or a foreign country.

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).

First Interstate will collect information regarding the ultimate beneficial owner(s) and control person of legal entities whether or not they have a personal relationship with the financial institution.

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

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 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.

Why has First Interstate been asked to collect this information?

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

Is First Interstate the only bank that is required to collect beneficial ownership information?

All financial institutions are required to comply with Bank Secrecy Act regulations and will collect beneficial ownership information from applicable customers to comply with these regulations.

What information does a Legal Entity need to provide?

The beneficial owner final rule expands upon the 2003 Customer Identification Program requirements which required the collection of and verification of customer name, date of birth, address and tax identification number.

The extension includes the identification of those natural persons defined as beneficial owners of a legal entity.

Beneficial owners can be defined in two ways:

Ownership prong: Each individual who, directly or indirectly, owns 25% or more of the equity interests of the legal entity customer.
Control prong: One individual with significant responsibility to control, manage or direct the legal entity customer, and their corresponding title (e.g. Chief Executive Officer, Chief Operating Officer, President, Vice President, and Managing Member).

Some exclusions may apply.

What documentation is collected on an identified Beneficial Owner?

Beneficial ownership information will be collected at account opening for new accounts and anytime a beneficial owner of the legal entity changes.
Information required for the Ownership and Control Prong individuals include:

Full Name
Date of birth
Address (residential or business street address, no P.O. Boxes)
Social security number or ITIN (for U.S. persons or permanent resident aliens)
In lieu of SSN/ITIN, a copy of a passport or U.S. government-issued document evidencing nationality or residence and bearing a photograph (for non U.S. persons)
Percentage of ownership (ownership prong)
Title (control prong)

The natural person opening the account on behalf of the legal entity will be required to be an authorized signer and sign a certification form attesting that the information provided on beneficial ownership is complete and correct.

What if the people who have been identified as beneficial owners or control persons are not clients of First Interstate? Do I still need to provide their personal information to First Interstate?

Yes. Regardless of customer status, information about the ultimate beneficial owners and control person must be provided in order to comply with the regulation.

My First Interstate representative has asked me for a Certification of Beneficial Ownership. What is this and why is it necessary?

The Certification of Beneficial Ownership is a legally required form that First Interstate 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.

Where will beneficial ownership data be stored?

First Interstate 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.

Will the information I provide for beneficial ownership be used for marketing to prospects that do not already have a relationship with First Interstate?

No. This information will not be used for marketing or prospecting purposes.

How do I get beneficial ownership information back to my First Interstate representative?

Beneficial ownership information will be collected using First Interstate documents and should be returned to your First Interstate representative.

Given the sensitive nature of the information that is being provided for beneficial ownership, can I provide the details directly to my First Interstate representative?

Yes. If you are more comfortable providing information in person, please reach out to your First Interstate representative directly.

I also have personal accounts with First Interstate. Will First Interstate also collect beneficial ownership information for my personal accounts?

No, the beneficial ownership rule does not apply to individuals.