Customer Due Diligence and Beneficial Ownership Requirements FAQs

Beginning May 2018, new federal regulation requires all non-exempt business customers at Heartland and its member banks will be required to provide additional information on beneficial owners, control persons, and the individual opening the account.

This information will be collected on the beneficial ownership certification form.


Who must complete this form?

This form must be completed by the person opening a new account on behalf of a legal entity.

For the purposes of this form, a legal entity includes a corporation, limited liability company, or other entity that is created by a filing of a public document with a Secretary of State or similar office, a general partnership, and any similar business entity formed in the United States or a foreign country. Legal entity does not include sole proprietorships, unincorporated associations, or natural persons opening accounts on their own behalf.


What information do I have to provide?

This form requires you to provide the name, primary residence address, date of birth and Social Security number (or passport number or other similar information, in the case of foreign persons) for the following individuals (i.e., the beneficial owners and controlling person):

  1. Each individual, if any, who owns, directly or indirectly, 25% or more of the equity interests of the legal entity customer (e.g., each natural person that owns 25% or more of the shares of a corporation); and
  2. An individual with significant responsibility for managing the legal entity customer (e.g., a Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President, or Treasurer).

The number of individuals that satisfy this definition of “beneficial owner” may vary. Under section (B), depending on the factual circumstances, up to four individuals (but as few as zero) may need to be identified. Regardless of the number of individuals identified under section (B), you must provide the identifying information of one individual under section (C). It is possible that in some circumstances the same individual might be identified under both sections (e.g., the President of Acme, Inc. who also holds a 30% equity interest). Thus, a completed form will contain the identifying information of at least one individual (under section (C)), and up to five individuals (i.e., one individual under section (C) and four 25% equity holders under section (B)).

We may also ask to see a copy of driver’s license or other identifying document for each beneficial owner and control person on this form.

For more information on this new regulatory requirement, please refer to the following federal government overview: https://www.gpo.gov/fdsys/pkg/FR-2016-05-11/pdf/2016-10567.pdf