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The Beneficial Ownership Rule

Federal regulation requires us to obtain, verify, and record information about beneficial owners of Legal Entity customers.

Beneficial Ownership is a new rule from the Financial Crimes Enforcement Network (FinCEN), under the Bank Secrecy Act, which requires all covered financial institutions to collect and verify from certain non-exempt legal entities specific information about the beneficial owners of the entity at the time a new account is opened. The intent of the Beneficial Ownership Rule is to assist authorities in counteracting money laundering, tax evasion, and other financial crimes.

  • Effective May 11, 2018, new rules under the Bank Secrecy Act will aid the government in the fight against crimes to evade financial measures designed to combat terrorism and other national security threats.
  • Each time an account is opened for a covered Legal Entity, we are required to ask you for identifying information (name, address, date of birth, social security number) and identification documents (unexpired driver’s license, passport, etc.)


form  The Beneficial Owner Form

When opening an account at First National Bank, the Beneficial Ownership Form must be completed by the NAP.  The form requires, among other information,  the name, business address or primary residence address, date of birth, Social Security Number (as applicable), the name of the issuing state or country, and number of the passport or driver’s license for the Beneficial Owners and Control Person as applicable.

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You can review the form at any time to become familiar with it. 

To complete the Beneficial Ownership Form, please save it to your computer.  It can be completed as a PDF form but must then be printed as a hard copy; the Natural Authorized Person must sign in ink (“wet” signature).  The completed and signed form may be scanned and returned to the bank as directed by a First National Bank representative or a paper copy may be brought to all new account openings.

First National Bank will verify the information provided.

warning Who does this change affect?

The following people will be required to provide the appropriate documentation required by federal regulation:

  • Each individual that owns 25% or more of the Legal Entity AND
  • One individual that has significant managerial control of the Legal Entity

Legal Entities do not include sole proprietorships, unincorporated associations, or a natural person opening accounts on their behalf.


  • Each time you open an account (checking, savings, loan, CDs, safe deposit box, etc.) you will be required to provide the appropriate documentation (name, address, date of birth, social security number as well as identification documents) and to certify that the information is true and accurate to the best of your knowledge. We are required to ask you for this information each time an account is opened for a covered Legal Entity.
  • If there were changes in beneficial ownership since last certifying for your organization.

  • As may be requested by First National Bank.

Which Entities are Excluded and Exempt?

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