New Regulation Regarding Beneficial Ownership
OverviewIn May 2016, the U.S. government passed a new regulation regarding the beneficial ownership of legal entity customers. Going forward, it will be mandatory for all financial institutions to comply with this regulation by identifying the ultimate beneficial owner(s) and a controlling person of a legal entity customer opening or maintaining an account.
In compliance with this new regulation, Pike National Bank (herein known as “PNB”) will collect beneficial ownership information from legal entity customers starting in the first quarter of 2018. This means that any time an account is opened or maintained for a legal entity, we will request information that identifies the ultimate beneficial owner(s) and controlling person of the legal entity. The required identifying information includes name, address, date of birth, identification number, and other information that will help identify those individuals. This information will need to be collected whether or not the person identified is as a PNB client. This information will also be collected for existing legal entity customers who establish or maintain accounts once this new regulation is implemented at PNB in the first quarter of 2018.
While we understand the information requested is personal and sensitive, we need to obtain this information in order to comply with the law. As always, we will treat all information collected with the utmost care. All information will be stored securely and handled with the same standard of privacy that we have always maintained.
What you need to know about Beneficial Ownership:• The new regulation impacts all legal entities opening or maintaining accounts at any financial institution.
• Legal entities will need to identify and attest to all ultimate beneficial owner(s) that meet specific requirements as well as a controlling person (e.g., Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President or Treasurer).
• PNB will collect information regarding the ultimate beneficial owner(s) and control person of legal entities whether or not they have a personal relationship with the financial institution.
We appreciate your business and are committed to providing you with extraordinary service for years to come.
Frequently Asked Questions• What is the beneficial ownership regulation and why does it matter?
The beneficial ownership regulation is a federal law requiring all financial institutions to identify and verify the identity of the beneficial owners of legal entity customers as well as a controlling person of the legal entity anytime an account is opened or maintained. The regulation is aimed at making financial institutions safer for their customers and protecting the country’s financial system.
• Why has PNB been asked to collect this information?
PNB, as well as all other financial institutions in the U.S., will be required to collect beneficial ownership information. The U.S. government implemented the new beneficial ownership regulation to help fight financial crimes. PNB is doing its part in upholding the new regulation to protect the financial system. Compliance with regulations has always been of utmost importance to PNB, and the new beneficial ownership regulation will be treated with the same level of importance.
• Is PNB the only bank that is required to collect beneficial ownership information?
No. All financial institutions are required to comply with the new beneficial ownership regulation and will be collecting this beneficial ownership information from applicable customers.
• What constitutes beneficial ownership?
The U.S. government regulation defines “beneficial ownership” as being made up of two roles: (1) those that have an ownership interest in a legal entity and (2) those that control a legal entity. For those people who have an ownership interest in the legal entity, PNB is required to identify and collect personal information on anyone that meets or exceeds the following ownership thresholds:
Ultimate Beneficial Owners:
1. A natural person having 25 percent or more of the equity interests of a legal entity; or
2. A natural person owning more than 10 percent if:
a. An individual, with any amount of ownership, is a non-U.S. person (i.e., a non-U.S. citizen who is not a lawful permanent resident); or
b. The entity customer or intermediary entity is formed outside of the U.S.; or
c. The entity client is a Private Investment Companies (PICs) / Personal Investment Vehicles (PIVs).
1. A person with significant managerial control or influence over a legal entity customer (e.g., Chief Executive Officer, Chief Financial Officer, Managing Member, General Partner, etc.) For every legal entity client subject to beneficial ownership, you must identify one control person.
NOTE: It is possible that the control person may also be an ultimate beneficial owner.
• How will the change impact my existing accounts?
The change should not impact your existing accounts. However, please be aware that your PNB representative may reach out for beneficial ownership information to update your account file, ensuring necessary compliance for any future financial requests.
• What if the people who have been identified as beneficial owners or control persons are not clients of PNB? Do I still need to provide their personal information to PNB?
Yes. Regardless of customer status, information about the ultimate beneficial owners and control person must be provided in order to comply with the regulation.
• My PNB representative has asked me for a Certification of Beneficial Ownership. What is this and why is it necessary?
The Certification of Beneficial Ownership is a legally required form that PNB must collect from legal entity customers regarding their ultimate beneficial owners and the control person. By completing the form, you are attesting that the information provided is accurate to the best of your knowledge.
• Where will beneficial ownership data be stored?
PNB will maintain beneficial ownership information in its system of record. We maintain strict privacy policies and procedures. Any client information, including beneficial ownership information, will not be shared.
• Will the information I provide for beneficial ownership be used for marketing to prospects that do not already have a relationship with PNB?
No. This information will not be used for marketing or prospecting purposes.
• How do I get beneficial ownership information back to my PNB representative?
Beneficial ownership information will be collected using PNB documents and should be returned to your PNB representative.
• Given the sensitive nature of the information that is being provided for beneficial ownership, can I provide the details directly to my PNB representative?
Yes. If you are more comfortable providing information in person, please reach out to your PNB representative directly.
• I also have personal accounts with PNB. Will PNB also collect beneficial ownership information for my personal accounts?
No. The Beneficial Ownership regulation only applies to applicable legal entity accounts.
For more information on beneficial ownership, please contact your relationship manager.
EQUIFAX - Cybersecurity Incident & Important Consumer Information
September 18, 2017
Recently, Equifax, one of the three national consumer credit reporting agencies, announced a major data breach. This breach affects approximately 143 million Americans. This is what we know according to Equifax: the data breach occurred May – July 2017, and the information stolen includes consumers’ personally identifiable information, including names, Social Security numbers, dates of birth, addresses and, in some cases, driver’s license numbers. Approximately 209,000 credit card numbers and dispute documents with personally identifiable information for approximately 182,000 consumers were also stolen. There is no evidence of unauthorized access to consumers’ credit reporting databases.
To be clear, Pike National Bank was not compromised and your information was not stolen from our bank. However, Pike National Bank takes the security of our customer information very seriously, and we are providing you with the information we know about this massive breach and the steps you can take to protect your personally identifiable information if you so desire. Following this unprecedented breach, we are also asking our customers to be extra vigilant and report any suspicious activity in your Pike National Bank accounts to Account Services by calling 601-684-7575 ext. 400.
Equifax has established a website that informs consumers if they may be affected by the breach, provides additional information on the breach, and offers complimentary identity theft protection and credit file monitoring. This information is available at www.equifaxsecurity2017.com. To protect your identity and personal information, Pike National Bank strongly encourages our customers to take the actions noted below.
- Review your account statements to spot any suspicious transactions. You can also monitor your account activity online at any time at www.pnb-ms.net.
- If you spot any suspicious transactions, please contact us immediately at 601-684-7575 ext 400.
- Consider if you should place an initial fraud alert on your credit report (see https://www.consumer.ftc.gov/articles/0275-place-fraud-alert).
- Consider if you should freeze your credit file (see https://www.consumer.ftc.gov/articles/0497-credit-freeze-faqs).
- Review your credit reports for accuracy. Call any one of the three credit reporting agencies to receive your free annual credit report or visit www.annualcreditreport.gov.
P.O. Box 9554
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P.O. Box 2000
Chester, PA 19016
P.O. Box 740241
Atlanta, GA 30374
- You should also contact the credit reporting agencies to notify them of any suspected fraud or identity theft.
If you believe you are the victim of identity theft, contact your local law enforcement office and/or your state attorney general. Finally, you may also want to consider reviewing information about recovering from identity theft, which is available from the Federal Trade Commission (FTC) at https://www.identitytheft.gov/ or by calling 1-877-IDTHEFT (1-877-438-4338). The FTC also offers general information to protect your online presence at https://www.consumer.ftc.gov/topics/privacy-identity-online-security.
Equifax has established a dedicated toll-free number to answer questions you may have about the Equifax data breach and its effect on your personally identifiable information. You may call them at 866-447-7559.
Pike National Bank
Reminder about Fraud Prevention
The best fraud prevention available is you! Learn to identify fraud so that you can protect yourself!
Scammers are becoming more and more creative. Be on the lookout for people who are giving you a
get-rich-quick opportunity, or charities you’ve never heard of. If it seems too good to be true, it probably is!
Another sign of fraud is if someone offers to deposit money into your account (or you receive a check in the mail to be deposited), and then asks you to withdraw that money and send it back to them to by a prepaid Visa card or wire. By the time the money they sent comes back as fraud, they have your money and you are responsible for the bill!
Remember: The goal of fraud is to take your money! It is always harder to get money back than it is to keep it in the first place!
Be extremely cautious about giving any of your personal information out over the phone, especially if they called you first! Personal information includes your bank routing and account numbers, your online banking user ID and password, and any other unique information like your date of birth or Social Security numbers.
If you think something may be fraud, ask us! Count on your bankers at PNB to help you
identify fraud and stop it!
Our Fraud Prevention Service
In our continuing efforts to keep your accounts secure, we've improved our alert system for potential fraud. If suspected fraudulent transactions are detected on your debit card, the following efforts to contact you will be made.
Here's how it works:
- When potential fraud is detected, you will receive an automatic email notification from Pike National Bank, with the option to reply "fraud" or "no fraud."
- One minute after the email, you will receive a text alert from #32874 between 7am and 9pm, which also has the "fraud" or "no fraud" option. The text message alerts will only be received by customers who use the following cell phone carriers: AT&T, Verizon, Sprint, Boost, Virgin Mobile, and T-Mobile.
- If you do not respond within five minutes of the text alert, you will receive an automatic phone call to confirm or deny fraud .
Remember - our messages will never ask for your PIN or account number.
*The phone number for our Fraud Center has changed to 1-800-417-4592 . If you add this number to your phone contacts and label it "Fraud Center," it will display whenever you get a call from this number.
Debit Card Monitoring
In an effort to better detect fraudulent activity on PNB’s customers’ debit cards, we have engaged the services of a Fraud Center to monitor debit card activity 24 hours a day, 7 days a week. With this enhanced monitoring, you may be contacted between 8:00 am and 9:00 pm to verify any potential fraudulent activity.
They WILL NOT ask for any personal information. They will disclose that they are calling on behalf of Pike National Bank and will only ask for verification of the transaction in question.