Beneficial Ownership

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

Highland 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. Highland 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 Highland Bank, and the new beneficial ownership regulation will be treated with the same level of importance.

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.

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, Highland Bank is required to identify and collect personal information on anyone that meets or exceeds the following ownership thresholds:

Ultimate Beneficial Owners:

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

A natural person owning more than 10 percent if:

• An individual, with any amount of ownership, is a non-U.S. person (i.e., a non-U.S. citizen who is not a lawful permanent resident); or
• The entity customer or intermediary entity is formed outside of the U.S.; 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 an ultimate beneficial owner.

In most instances, a copy of a valid driver’s license will meet Highland Bank’s identification requirements and can be provided in person or via secure email.  Please reach out to your Highland Bank relationship manager to obtain the specifics regarding identification requirements.

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

The Certification of Beneficial Ownership is a legally required form that Highland Bank 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.

Highland 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.

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

Beneficial ownership information will be collected using Highland Bank documents and should be returned to your Highland Bank relationship manager.

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