Pub. 12 2017-2018 Issue 6

WWW.NEBANKERS.ORG 26 Schedule a tour or demo today! Contact Tracy Dreessen, Cash Vault Services Sales Coordinator Call: 800/558-9323 E-mail: tdreessen@rocarmco.com Visit: RochesterArmoredCar.com Cash Vault Services Secure currency and coin storage Cash order preparation and deposit verification Inventory management Access to a secure web portal Reduce risk. Improve efficiencies. Lower costs. All with one service. use the model form but it’s not a requirement; you can record that information in some other fashion. The person opening the account must certify the information is correct, regardless of how it’s collected. Step 6: When Do I Have to Collect? This informationmust be collected every time a legal entity opens a new account—even if the entity has banked with the bank for 20 years. The FDIC has indicated that auto-renewals of CDs do not trigger beneficial ownership requirements. However, con- flicting opinions have arisen on this topic, so it’s always best practice to obtain an interpretation of the regulation directly from your regulator. So, there’s the rule! It’s similar to CIP but requires more organization information from your business customers.  Silvia Garcia Maggio serves as an associate general counsel for Compliance Alliance. After graduating from The University of Texas School of Law in 2011, she began her career in real property and foreclosure law. Employed by a national mortgage servicer since 2012, she worked on the OCC independent foreclosure audit and in compliance for Enterprise Risk Management, gaining a multitude of experience dealing with multi-state and federal banking regulations. Garcia Maggio began working at Compliance Alliance in March 2014 and is currently part of the team of attorneys who assist CA members with a wide range of regulatory and compliance inquiries. Over the past year, she has developed and implemented the C/A Minute videos, a series of short, compliance training and refresher videos that leverage the frequently asked questions from the Compliance Alliance hotline. In addition, she regularly presents on a number of compliance topics at regulatory schools and conferences nationwide. Compliance Alliance offers a comprehensive suite of compliance management solutions, including a full BSA/AML compliance toolkit with beneficial ownership tools. To learn how to put them to work for your bank, call 888-353-3933 or email info@compliancealliance.com . You also may register for a free online demo at http://bit.ly/CAdemos. For timely compliance updates, subscribe to the Compliance Alliance email newsletter at http://eepurl.com/bjXIVv . Beneficial Ownership — continued from page 25