Beneficial Ownership

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What is the Beneficial Ownership Rule?

Beneficial Ownership is a requirement from the Financial Crimes Enforcement Network (FinCEN), under the Bank Secrecy Act, which mandates all covered financial institutions, including McHenry Savings Bank, 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. FinCEN requires all financial institutions to begin collecting the required information for new accounts opened no later than May 11, 2018.

What is the NEW Beneficial Ownership and Required Reporting Rule effective January 1, 2024?

The Reporting Rule requires certain entities to file Beneficial Ownership Information (BOI) reports (referenced in the FinCEN Beneficial Ownership Reference Guides) to FinCEN. Reports contain information about the entity itself and two categories of individuals:

Beneficial Owners - (Owns or controls at least 25% of the ownership interest of a reporting company)
All individuals who exercise substantial control over the company

Starting on January 1, 2024, BOI reports must be filed electronically using FinCEN’s secure filing system. FinCen will store BOI reports in a centralized database and only share this information with authorized users for purposes specified by law. The database will use rigorous information security methods and controls typically used in the Federal government to protect non-classified yet sensitive information systems at the highest security level.

When do I need to file a report?

Reports will be accepted starting on January 1, 2024
Reporting companies created or registered to do business before January 1, 2024, will have additional time — until January 1, 2025 — to file their initial BOI reports.
Reporting companies created or registered on or after January 1, 2024, will have 30 days after receiving notice of their company’s creation or registration to file their initial BOI reports.

Where can I find additional information about BOI reporting?

Additional information about the Reporting Rule and guidance materials are available at www.fincen.gov/boi.

Document Requirements for Opening a Business Deposit Account

Complete MSB’s New Business Account Application and Business eBanking Application

Business Deposit Account Requirements