Beneficial Ownership

Beneficial Ownership 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 Metairie Bank been asked to collect this information?

  Metairie Bank, 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. Metairie Bank is doing its part in upholding the new regulation to protect the financial system. Compliance with regulations has always been of utmost importance to Metairie Bank, and the new beneficial ownership regulation will be treated with the same level of importance.

• Is Metairie Bank the only bank 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 constitutes 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, Metairie Bank is required to identify and collect personal information on anyone that meets or exceeds the following ownership thresholds:

  Beneficial Owners:

  A natural person having 25 percent or more (directly or indirectly) of the equity interests of a legal entity; or

  Control Person:

  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 client subject to beneficial ownership, you must identify one control person.

   NOTE: It is possible that the control person may also be a beneficial owner.

• How will the change impact my existing accounts?

  The change should not impact your existing accounts. However, please be aware that your Metairie Bank representative may reach out for beneficial ownership information to update your account file, ensuring necessary compliance for any future financial requests.

• What if the people who have been identified as beneficial owners or control persons are not clients of Metairie Bank? Do I still need to provide their personal information to Metairie Bank?

  Yes. Regardless of customer status, information about the beneficial owners and control person must be provided in order to comply with the regulation.

• My Metairie Bank representative has asked me for a Certification of Beneficial Ownership. What is this and why is it necessary?

  The Certification of Beneficial Ownership is a legally required form that Metairie Bank must collect from legal entity customers regarding their 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.

• Where will beneficial ownership data be stored?

  Metairie Bank will maintain beneficial ownership information in its system of record. We maintain strict privacy policies and procedures. Any client information, including beneficial ownership information, will not be shared.

• Will the information I provide for beneficial ownership be used for marketing to prospects that do not already have a relationship with Metairie Bank?

  No. This information will not be used for marketing or prospecting purposes.

• How do I get beneficial ownership information back to my Metairie Bank representative?

  Beneficial ownership information will be collected using Metairie Bank documents and should be returned to your Metairie Bank representative.

• Given the sensitive nature of the information that is being provided for beneficial ownership, can I provide the details directly to my Metairie Bank representative?

  Yes. If you are more comfortable providing information in person, please reach out to your Metairie Bank representative directly.

• I also have personal accounts with Metairie Bank. Will Metairie Bank also collect beneficial ownership information for my personal accounts?

  No. The Beneficial Ownership regulation only applies to applicable legal entity accounts.