Member question: “One of our banks does a biannual KYC [know your customer] refresh and asks us to complete the US Client Certification of Beneficiary Ownership (a FinCEN form).
- “Is this something that your company also provides, and do you include Social Security number info?”
Peer answer 1: “You do not need to provide SSN for a non-US person and you need to provide only one such person.”
Peer answer 2: “We always put the parent US company as the UBO [ultimate beneficial owner], and we would use the TIN [taxpayer identification number] number as SSN. If they don’t accept the parent company, we would use a foreign board member, which would avoid the need to provide SSN. We never ask for anyone’s SSN or provide them.”
Peer answer 3: “Our company worked out a process with our major relationship banks whereby we created our own ‘non-standard’ FinCEN CDD [customer due diligence] form identifying our beneficial owners. This form does include their SSN #.
- “We provide the form to our US relationship contact and ask them to keep it secure and distribute internally within the bank on an as-needed basis any time FinCEN CDD requests need to be satisfied. It has worked very well for us and has eliminated providing this information multiple times.”
Peer answer 4: “We typically refuse to provide SSNs and work with the counterparty to find an alternative.”
Peer answer 5: “We do share a SSN. I believe our bank requests an update every three years; maybe you can encourage this bank to do the same.”
Peer answer 6: “I have a request right now from a bank. They won’t let us use the parent company as the BO [beneficial owner]; they insist on an individual. I pushed back, asking them to show me the regulation that calls for the SSN or work with me on an alternative.”