BankingTalking Shop

Talking Shop: For a Bank KYC Refresh, Do You Complete a Beneficial Ownership Form With SSN?

By October 20, 2020No Comments

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.”

Justin Jones

Author Justin Jones

More posts by Justin Jones