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Beneficial Ownership Requirements for Legal Entity Clients

What It Is and What It Means for Businesses

To help the government fight financial crime, financial institutions, including Webster, are required to verify the identity of their clients by obtaining, verifying and recording information about the Equity (“Beneficial”) Owners of certain Legal Entity customers.

Which legal entities are required to provide Beneficial Ownership information to Webster?

For the purposes of this regulation a Legal Entity includes a Corporation, Limited Liability Company, General Partnership, or other entity that is created by a filing of a public document with a Secretary of State or similar office.

A Legal Entity does not include sole proprietorships, unincorporated associations, publicly traded companies (American, NY, NASDAQ), public accounting firms, non-statutory trusts/estates, entities registered with the SEC, CTA or SEA, municipalities, government entities, regulated banks, employee benefit plans established under ERISA, or other regulated entities. Other exclusions may apply.

What is a Beneficial Owner?

  • Any individual who directly or indirectly owns 25 percent or more of the Legal Entity customer, AND
  • One individual with significant responsibility for managing the Legal Entity customer, such as President, Vice President, General Partner, Managing Member, Chief Operating Officer, Chief Financial Officer or Chief Executive Office.
    • A business may not be listed as an owner of the Legal Entity. If another business is part owner of your company you must determine if ANY individual (natural person) indirectly owns 25% of your company. If any such individual exists meeting this criterion they should be listed in the ownership section of the form.
    • For example: If ABC Inc. is owned by one or more other businesses, you must determine if any individual that owns those other businesses indirectly owns 25% or more of ABC Inc.

What will Webster do with this information?

The information is maintained as part of your Webster Bank N.A. account record. Please be assured that all client information is kept in the strictest confidence, except as required by law or may be permitted by law to be disclosed.

Federal Register Website

For additional guidance related to the Beneficial Ownership Rule and Requirements.

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