What Information Does FCB Request from Customers?
Why FCB Asks Customers Questions?
In May 2016, FinCEN issued a final rule for Customer Due Diligence Requirements for Financial Institutions (“CDD Rule”) formalizing regulatory expectations regarding customer due diligence (CDD) and introducing a new requirement for financial institutions to identify and verify the identity of the beneficial owners of their legal entity customers1. Specifically, the Final CDD Rule imposes a requirement on financial institutions to identify and verify the identity of certain legal entity customers’ “beneficial owners” defined as: (i) each individual directly or indirectly owning 25% or more of the entity’s equity interests, and (ii) a single individual with significant responsibility to control, manage or direct a legal entity customer.
The CDD Rule specifically requires all covered financial institutions to implement a CDD program that covers the following key elements:
- Identify and verify the identity of its customers;
- Identify and verify the identity of beneficial owners of legal entity customers (i.e. the natural persons who own or control legal entities);
- Understand the nature and purpose of the customer relationship; and
- Conduct ongoing monitoring.
The CDD Rule additionally requires that financial institutions implement a CDD Program that helps the Bank know its customers and understand the nature and purpose of customer relationships in order to create a customer profile. This includes, but is not limited to, understanding the type and volume of transactions that are anticipated through the account.
The Type of Information We May Ask You
- Place of Birth
- Nature of Business
- Beneficial Ownership
- Anticipated Transaction Activity
- Purpose of Transactions (May include supporting documentation on occasion)
- Major Vendors and Suppliers
- Revenues and/or Source of Funds
FCB [We] work to protect our customers, our company and the public at large from criminal activity by implementing a strong CDD Program. Everything you tell us is confidential, in accordance with the Bank Secrecy Act regulations, as well as, the Right to Financial Privacy Act regulations.
FCB Contact Information
If you are asked to provide additional CDD information and you have questions, you may contact the [Customer Due Diligence Department] at 1-866-461-9383.
If you have the ability to send encrypted and/or secured emails and would prefer to respond to a request for additional CDD information electronically, you may submit your response to the following email: RFIResearch@fcb1923.com.
For Your Safety
On occasion, FCB may contact you at the phone number provided on file. Should this occur, the Bank may ask you a couple of questions to authenticate that the person reached is actually you.
Should you have any concerns about answering questions via phone contact, you may submit your responses through the secure email provided: RFIResearch@fcb1923.com. In order to protect your information, FCB will provide you with a customer code to identify you as a customer. Please submit this code when making an inquiry or response to any CDD questions that the Bank may request from you.
1. See 31 C.F.R. §1010.230. See also FinCEN -2016-G003, Frequently Asked Question Regarding Customer Due Diligence Requirements for Financial Institutions (July 19, 2016).