Effective May 11, 2018, new rules under the Bank Secrecy Act will aid the government in the fight against crimes to evade financial measures designed to combat terrorism and other national security threats.
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.
The new regulation impacts all legal entities opening or maintaining 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).
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.
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.
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.
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 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:
Some exclusions may apply.
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:
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.
The change should not impact your existing accounts. However, please be aware that your First Interstate representative may reach out for beneficial ownership information to update your account file, ensuring necessary compliance for any future financial requests.
Yes. Regardless of customer status, information about the ultimate beneficial owners and control person must be provided in order to comply with the regulation.
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.
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.
No. This information will not be used for marketing or prospecting purposes.
Beneficial ownership information will be collected using First Interstate documents and should be returned to your First Interstate representative.
Yes. If you are more comfortable providing information in person, please reach out to your First Interstate representative directly.
No, the beneficial ownership rule does not apply to individual.