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Beneficial Ownership

What's this all about?

Beneficial Ownership


To help the government fight financial crime, Federal regulation requires certain financial institutions to obtain, verify, and record information about the beneficial owners of legal entity customers. Legal entities can be abused to disguise involvement in terrorist financing, money laundering, tax evasion, corruption, fraud, and other financial crimes.  Requiring the disclosure of key individuals who own or control a legal entity (i.e. the beneficial owners) helps law enforcement investigate and prosecute these crimes. 

In 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, Farmers and Merchants Bank will collect beneficial ownership information from legal entity customers starting May 1, 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 a Farmers & Merchants Bank client.  This information will also be collected for existing legal entity customers who establish or maintain accounts once this new regulation is implemented at Farmers and Merchants Bank.

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.  (Sole proprietorships and public funds entities are not affected)
  • 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).
  • Farmers and Merchants Bank 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.


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.



FMB, 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. FMB is doing its part in upholding the new regulation to protect the financial system. Compliance with regulations has always been of utmost importance to FMB, and the new beneficial ownership regulation will be treated with the same level of importance.

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.

The change should not impact your existing accounts. However, please be aware that an FMB representative may request beneficial ownership information to update your account file, ensuring necessary compliance for any future financial requests.

Yes. Regardless of customer status, information about the beneficial owners and control person must be provided in order to comply with the regulation.

FMB will maintain beneficial ownership information in its secure account information environment . We maintain strict privacy policies and procedures. Any client information, including beneficial ownership information, will not be shared.

No. This information will not be used for marketing or prospecting purposes.

No. The Beneficial Ownership regulation only applies to applicable legal entity accounts.