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Effective May 11, 2018, the government is requiring all banks to comply with new rules under the Bank Secrecy Act that will aid the government in the fight against crimes to evade financial measures designed to combat terrorism and other national security issues. This is referred to as the Beneficial Ownership Rule that applies to each new account that is opened by a legal entity. Examples of legal entities would include corporations, limited liability companies, partnerships, business trust filed with the state or other similar business entities. There are 2 prongs for the definition of beneficial owner:

• Ownership – each individual, who directly or indirectly, owns 25% or more of the equity interests of a legal entity customer
• Control – one individual with significant responsibility to control, manage or direct a legal entity customer (e.g. CEO, CFO, COO, Managing Member, General Partner, President, Vice President or Treasurer) OR any other individual who performs similar functions

At the time an account is opened or renewed (deposit or loan), the Certificate of Beneficial Ownership form is required to be completed. This form requires you to provide the name, address, date of birth and Social Security Number (or passport number or other similar information, in the case of foreign persons), as well as identification documentation (i.e. unexpired government issued ID with current physical address), for all individuals who fit the definition of beneficial owner. You will be required to provide this information and certify that this is true and accurate to the best of your knowledge before the account can be opened.

In order to make this process as efficient as possible, we are notifying you in advance to obtain the required information (name, address, date of birth, SSN and copy of ID) for each individual under the Ownership & Control prongs. If your business will frequently be opening new accounts and/or loans, we recommend you keep this information current and available as it will be required EACH time you establish a new account.