When opening an account or revising an account for specific business entities, consult the tabs and perform the actions by the type of entity.
See Monitoring High Risk Accounts for more information.
For details on account opening, see Opening a New Corporation Account and Opening a New Limited Liability Corporation (LLC).
Money Services Businesses (MSB)
Before opening an MSB account, obtain Bank Secrecy Act (BSA) officer approval. To obtain BSA approval, do the following:
- Complete a Money Services Business (MSB) Agreement.
- E-mail the completed agreement to _BSA Department.
- Include details about the client and any relationship details.
- If the BSA officer approves the account opening, print the approval e-mail.
- Include the printed e-mail approval with the new account documents.
If the account is approved by the BSA Department, collect the following documents:
- Copies of state license
- FinCEN registration
- Agent agreements
- Anti-money laundering compliance program
- Most recent audit
Money service business accounts are subject to the following:
- Money service activity is required to be separated into an independent account
- The account title must include MSB Account
- A service fee code of MBis added to assess the monthly fee
- For details on fees, click here to access the Other Services and Fees brochure.
- ALL cash supporting the money service activity must be withdrawn as cash from the money service account
- ALL cashed checks or other related electronic credits must be deposited into the money service account
Check Casher
Before opening a Check Casher account, obtain BSA officer approval. To obtain BSA approval, do the following:
- Complete a Check Casher (CC) Agreement.
- E-mail the completed agreement to _BSA Department.
- Include details about the client and any relationship details.
- If the BSA officer approves the account opening, print the approval e-mail.
- Include the printed e-mail approval with the new account documents.
If the account is approved by the BSA Department, collect the following documents:
- Copies of state license
- FinCEN registration
- Agent agreements
- Anti-money laundering compliance program
- Most recent audit
Check casher accounts are subject to the following:
- Check cashing activity is required to be separated into an independent account.
- The account title must include Check Casher Account.
- A service fee code of MCis added to assess the monthly fee.
- For details on fees, click here to access the Other Services and Fees brochure.
- ALL cash supporting the check cashing activity must be withdrawn as cash from the check-cashing account.
- ALL cashed checks or other related electronic credits must be deposited into the check cashing account.
Privately-owned ATM (PATMO)
Before opening a PATMO account, obtain BSA officer approval. To obtain BSA approval, do the following:
- Contact the BSA officer (or designee) to obtain approval to open the account.
- Once the account is approved, complete a Privately Owned ATM (PATMO) Account Request form.
- E-mail the completed form to _BSA Department.
- Include details about the client and any relationship details.
- If the BSA officer approves the account opening, print the approval e-mail.
- Include the printed e-mail approval with the new account documents.
If the account is approved by the BSA Department, collect the following documents:
- Copy of the Automated Teller Machine (ATM) agreement contract
- Location of the ATM
- ATM owner
- Source of funds for ATM cash replenishment
- Frequency of cash replenishment
PATMO accounts are subject to the following:
- Private ATM activity is required to be separated into an independent account.
- The account title must include PATMO Account.
- A service fee code of PTis added to assess the monthly fee.
- For details on fees, click here to access the Other Services and Fees brochure.
- ALL cash supporting the ATM activity must be withdrawn as cash from the PATMO account.
- ALL ATM electronic credits must be deposited into the PATMO account.
Nongovernmental Organizations / Charities
Obtain the following information for input into the client CDD questionnaire during account opening:
- Purpose and objectives of activities
- Geographic locations serviced
- Headquarters location
- Organization chart
- Donor/volunteer base
- Funding/Disbursement criteria
- Recordkeeping requirements
- Affiliations to other groups
- Internal audit control processes
Professional Service Providers
Obtain the following information for input into the Client Due Diligence (CDD) questionnaire during account opening:
- Purpose of the account
- Products/services offered
- The geographic location of clients serviced
Quick Reference Guide
Product Type
Commercial Business Checking
Legal Documents
Entity specific documents are required based on the business entity type for ALL new and revised accounts.
- Articles of Incorporation/Organization (if applicable)
- Partnership Agreement (if applicable)
- Verification of Active Status
- New accounts only
- CCB Affidavit
- Required for ALL revised accounts
- Updated or revised bylaws or meeting minutes documenting requested changes
- Required for ALL revised accounts
Verafin
Certification of Beneficial Owners of Legal Entities is REQUIRED FOR ALL NEW/REVISED ACCOUNTS.
See Business CDD Questionnaire.
DeleteCIP/CIF Requirements
- EIN Number for Business Entity
- Primary & Secondary ID viewed for ALL signers present
- Social Security Number for ALL signers present
- W8 BEN (Non-resident Alien ONLY)
Account Title and Signature Requirements
Title
MSB Account
ABC CONVENIENCE STORE
MSB ACCOUNT
Check Casher Account
ABC CONVENIENCE STORE
CHECK CASHER ACCOUNT
PATMO Account
ABC CONVENIENCE STORE
PATMO ACCOUNT
Signature
ALL Authorized Signers
DeleteCodes for Building the CIF
Class Code
- N - Non-Personal (Specific Entity)
- P - Personal (Signer)
Tax ID Code
- T - Business (Specific Entity & DBA with EIN)
- N - Non-Reporting Bus (DBA without EIN - leave blank)
- U - Foreign Business - (Foreign Business Entity)
- I - Individual - US Citizen or Resident Alien (Signer(s) present)
- B - Non Reporting Individuals (Signer(s) not present)
- F - Non-Resident Alien - ITIN (Signer)
- G - Non-Resident Alien - SSN Work Only (Signer)
- H - Non-Resident Alien - SSN Non Work (Signer)
- E - Non-Resident Alien - No TIN/DOES NOT meet the SPT (leave SSN field blank)
Identification Code (based on Specific Entity)
- AC - Articles of Corporation
- AO - Articles of Organization
- PA - Partnership Agreement
- Enter NA in the Identification Number Field
FinCen Legal Entity - Always Select “Exclude”
- Exclusion Reason
- CV - Capture in Verafin (Business)
- FP - Foreign Person (Non-Resident Alien)
- NP - Natural Person (US Citizen or Resident Alien)
Insider Code (if applicable)
- C - Community Board Member
- D - Director
- E - Associate
- O - Officer
- X - Executive Officer
Codes for Creating Account
Relationship Code
- P - Primary (Specific Entity)
- Y - SP/DBA/VTX (DBA)
- O - Officer (Signer)
- I - Influence (Signer)
Is client MSB, Check Casher, PATMO?
- MB - MSB - Money Service Business
- MC - Check Casher
- PT - PATMO - Private ATM Owner
Account Level Service Fees
- E - EDIT/ADD
- MB - Money Service Business
- MC - Check Casher
- PT - PATMO
Account Class Code
- Based on Specific Entity (for example: Corporation, LLC, Partnership)
Ownership
- Based on Specific Entity (for example: Corporation, LLC, Partnership)
Is this a Business Account Type?
- Y - Yes
Is Business a Foreign Entity?
- N - No
- Y - Yes (W8 BEN-E)
Is this a Fiduciary Account Type?
- N - No
Delete