Another wrinkle with the Section 1071 Rule that institutions need to be aware of involves the identification of the Principal Owner(s) (PO). Your lenders need to understand that Principal Owner(s) for 1071 are not necessarily the same people as the Beneficial Owner(s) (BO) under the BSA/AML rules. There will be instances where the POs and BOs are the same and instances where they are not. Lenders must understand the differences to maintain compliance with both requirements.
Find these resources here - https://store.bankerscompliance.com/link/LendingFD
Type "1071" in the search bar to find all your 1071 Resources.
We’ve put together a “Principal Owners vs. Beneficial Owners Comparison Chart (Version 1.0) ” to assist you in understanding the similarities and differences between a Principal Owners for 1071 and a Beneficial Owner for BSA/AML. It is available now in our Free Lending Tools.
Jerod explains the chart more here:
Stay tuned as we have more Section 1071 tools in process!
Published
2024/07/26
