Dear Business Customer:
 
Legislation by the US Department of the Treasury related to Customer Due Diligence and Beneficial Ownership was announced in 2016, with a mandatory implementation date in 2018. Due to these regulatory changes, beginning immediately we will be asking for additional information when commercial accounts are opened or changes are made to existing accounts held at First Southwest Bank. We are now required to gather information regarding Beneficial Owners of Legal Entity Customers as it relates to the following:
 
1) Ownership: Under the rule, any individuals who directly or indirectly own 25 percent or more of the equity interests in the legal entity must be identified. This means that up to four individuals may be identified; in some cases, however, there may not be any individual(s) identified under the ownership prong (for example, if no individual actually owns 25 percent or more of the equity interest).
 
2) Control: At least one individual must be identified who has significant managerial control over the legal entity customer. This individual could be an executive officer, a senior manager, or any other individual who regularly performs similar functions. An individual identified under the ownership prong above can also be identified under the control prong.
 
Certain exemptions will apply, for example sole proprietors and unincorporated associations.
 
At a minimum, the bank will request the legal name and structure of the entity and the name, date of birth, physical address, and social security number of all 25%+ owners and the control person. Also, a color copy of a valid driver’s license, passport or other government ID will be required for each owner, controller, and signer on the account or loan.
 
Each covered entity will be required to provide this information prior to document preparation for your new or renewed account with First Southwest Bank. We may also re-verify this information if we are made aware of a change in ownership, or there is a change in your relationship activity. To meet the Customer Due Diligence portion of this legislation, your Banker may also ask you more specific details about yourself, your business and expected use of the account.
 
We understand that this is a new requirement and we appreciate your understanding and cooperation with this required change. If you have any questions please contact your Lender, Banker or Branch Manager.
 
Best Regards,
First Southwest Bank Management

Member FDIC. Equal Housing Lender.
© 2016 First Southwest Bank
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