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Daniel P. Stipano Quoted in American Bankers Association Banking Journal Article, “Cui Bono? Banks Count Down to Compliance with the Beneficial Ownership Rule”

American Bankers Association Banking Journal

Daniel P. Stipano

Daniel P. Stipano was quoted on January 23, 2018 in an American Bankers Association Banking Journal article, “Cui Bono? Banks Count Down to Compliance with the Beneficial Ownership Rule,” which discussed the approaching implementation of the FinCEN final beneficial ownership rule and its various components. The article stated, “The final rule breaks down beneficial ownership into two ‘prongs’: an ownership prong and a control prong. Those who satisfy the ‘ownership’ prong are individuals who own 25 percent or more of the equity interests in the legal entity customer. The ‘control’ prong refers to a single individual that has authority to exercise control of the legal entity—typically a CEO, executive officer or treasurer.”

Stipano added, “In every case where you have a legal entity customer where no exclusion applies, you will have a minimum of one beneficial owner—because you’re always going to have a control person—and a maximum of five, if you use 25 percent as a benchmark. For any of those people, what you’re going to be doing is collecting the pieces of information you would collect for CIP [Customer Identification Program] purposes and then you’re going to verify that information, either through documentary means or non-documentary means.” He also noted that “the procedure you will ultimately use will be similar to your CIP procedures, but they may need to be tweaked, because a beneficial owner is not necessarily a customer. And that’s perhaps going to limit the information you’re entitled to see.” 

Click here to read the full article.