Hello,
Does anyone have a procedure and/or letter that you would be willing to share for when you believe a business account is no longer exempt from the CDD Beneficial Ownership Rule? We are a bit unique, because our credit union only allows sole proprietorship DBAs and unincorporated associations to open/maintain accounts. We do not open accounts for LLCs, Corporations, or any other business type that is not exempt from the rule. When a "triggering event" occurs our process is to confirm with the member that the business type has not changed. If the business type has changed, we inform the member that we can no longer maintain the account and then send a letter informing them that the account will be closed in 30 days. Does anyone else have a similar process? Also, what does your institution consider to be a triggering event?
Thank you in advance for your assistance.
