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SunState Federal Credit Union Business Products
- Owner-Occupied Commercial Real Estate
- SBA 504 Loans for Commercial Real Estate and Equipment
- Investment Commercial Real Estate
- Multi-Family Properties
- Lines of Credit
- Business Vehicle
- Business Checking
- Business Money Market
- Business Savings
- Business Certificates
- Same-day credit on deposits with no cutoff times
In May 2016, the U.S. government passed a new regulation regarding the beneficial ownership of legal entity customers. Going forward, it will be mandatory for all financial institutions to comply with this regulation by identifying the beneficial owner(s) and a controlling person of a legal entity member opening or maintaining an account.
What is Beneficial Ownership?
In compliance with this new regulation, SunState will collect beneficial ownership information from legal entity (business members) starting May 1, 2018. This means that any time an account is opened or changes are made for a legal entity (Business Account), we will request information that identifies the beneficial owner(s) and controlling person of the legal entity (Business Account). The required information will include name, address, date of birth, identification number, and other information that will help identify those individuals. This information will need to be collected whether or not the person identified is a SunState member. This information will also be collected for existing legal entity (Business Account) members who establish or update their account once this new regulation is implemented.
While we understand the information requested is personal and sensitive, we must obtain this information in order to comply with the regulation. As always, we will treat all information collected in confidence. All information will be stored securely and handled with the same standard of privacy that we have always maintained.
Frequently Asked Questions
What is the beneficial ownership regulation and why does it matter?
The beneficial ownership regulation is a federal law requiring all financial institutions to identify and verify the identity of the beneficial owners of legal entity customers as well as a controlling person of the legal entity anytime an account is opened or maintained. The regulation is aimed at making financial institutions safer for their customers and protecting the country’s financial system.
Why has SunState been asked to collect this information?
SunState, as well as all other financial institutions in the U.S., will be required to collect beneficial ownership information. The U.S. government implemented the new beneficial ownership regulation to help fight financial crimes. SunState is doing its part in upholding the new regulation to protect the financial system. Compliance with regulations has always been of utmost importance to SunState and the new beneficial ownership regulation will be treated with the same level of importance.
Is SunState the only financial institution that is required to collect beneficial ownership information?
No. All financial institutions are required to comply with the new beneficial ownership regulation and will be collecting this beneficial ownership information from applicable customers.
What denotes a beneficial ownership?
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, SunState 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 (Business) member subject to beneficial ownership, you must identify one control person.
How will the change impact my current accounts?
The change will not affect your day to day activity. However, please be aware that we may contact you for beneficial ownership information to update your account, ensuring we stay in compliance for any future financial requests.
What if the people who have been identified as beneficial owners or control persons are not members of the credit union? Do I still need to provide their personal information?
Yes. Regardless of beneficial owner’s status, information about the beneficial owners and control person must be provided in order to comply with the regulation.
Will I be asked to complete a Certification of Beneficial Ownership? What is this and why is it necessary?
The Certification of Beneficial Ownership is a legally required form that SunState must collect from legal entity customers regarding their ultimate beneficial owners and the control person. By completing the form, you are attesting that the information provided is accurate to the best of your knowledge.
Business Banking Team
Senior Vice President of Lending
Commercial Loan Officer