As of May 2018, it is mandatory for all financial institutions to comply with a new regulation regarding the disclosure of beneficial ownership of legal entities. This will not impact our consumer customers.
This means that any time an account is opened or maintained for a legal entity, we will request this information. The required identifying information includes the individual’s name, address, date of birth, Social Security number, and a government issued ID or other information that will help identify those individuals. This information will need to be collected whether or not the person identified is an Itasca Bank & Trust Co. customer.
This information will also be collected for existing legal entity customers who establish new accounts or make changes to existing accounts after May 2018.
We understand the information requested is personal and sensitive; however, we need to obtain this information in order to comply with the law. We will treat all information collected with the utmost care. All information will be stored securely and handled with the same standard of privacy that we have always maintained according to our Information Security Program.
We appreciate your business and are committed to working together to shape your future.
For questions on beneficial ownership, please contact your Loan Officer or a Relationship Banker at 630-773-0350.
The term “legal entity” includes business customers such as corporations and partnerships, but does not include the following:
Charities and non-profit organizations will only be required to provide information on one control person.
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, Itasca Bank & Trust Co. is required to identify and collect personal information on anyone that meets or exceeds the following ownership thresholds:
A natural person having 25 percent or more of the equity interests of a legal entity.
A person with significant managerial control or influence over a legal entity customer (e.g., Chief Executive Officer, Chief Financial Officer, Managing Member, General Partner, etc.)
For every legal entity customer subject to beneficial ownership, you must identify one control person.
NOTE: It is possible that the control person may also be a beneficial owner.