Beneficial Ownership FAQs

What is Beneficial Ownership and why are these changes occurring?
On July 11, 2016, new rules under the Federal Bank Secrecy Act went into effect. These new rules aid the government in the fight against crimes to evade financial measures designed to combat terrorism and other national security threats. Lowell Five Bank is putting this rule into effect on May 11, 2018.
Back to Top

What and Who is a “Beneficial Owner”?
For the purposes of this rule, it simply means a person who, directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise, owns 25% or more of the ownership interests of a legal entity.
Back to Top

My company is a sole proprietorship. Does this new rule apply to me?
No. If you are a Sole Proprietorship, the account opening process has not changed for you. This rule generally applies to Corporations, LLC’s, Limited Partnerships, General Partnerships and Business Trusts. It does not typically apply to Unincorporated Associations, most Non-Profits, and Personal Trusts.
Back to Top

What information do we need to provide to open a business account at Lowell Five Bank?
Each owner (25% or more ownership) will need to provide their: Name, Address, Date of Birth, Social Security Number. In addition, we will need one form of Primary Identification. The accepted forms are:

  • Current Primary Identification Documentation State Issued Driver’s License with photograph
  • U.S. Government Issued ID with photograph
  • U.S. Passport with photograph
  • U.S. Issued Armed Forces / Military ID with photograph State Issued Identification Card with photograph
  • Non-Resident Alien Identification Card w/ photo and number

Back to Top

What does “Significant Managerial Control” mean?
This is the person within the management structure who has significant responsibility to control, manage or direct the business. While there may be multiple people who can and will control the entity, we will require one individual.

Common examples: An executive officer or senior manager (e.g., a Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President, or Treasurer); or any other individual who regularly performs similar functions.
Back to Top

If I already have a business account with The Lowell Five Cent Saving Bank, is there anything I need to do?
No. However, if you open a new account, or make certain changes to your existing account (like changes of signers, officers or owners or significant changes in activity), then the new information will be required.
Back to Top