Dime’s Compliance to Beneficial Ownership

Understanding the new regulations.

In May 2016, the U.S. government passed a regulation regarding the beneficial ownership of legal entity customers. Going forward, financial institutions must comply with this regulation. They’ll do this by identifying the ultimate beneficial owner(s) and controlling person of legal entity customers opening or maintaining accounts.

Dime Community Bank will collect beneficial ownership information from legal entity customers to comply with this regulation. When opening or maintaining an account for a legal entity, we will request information identifying the ultimate beneficial owner(s) and controlling person. The required identifying information includes name, address, date of birth, and identification number. It also includes other details to help identify those individuals. This information will need to be collected whether or not the person identified is a Dime Community Bank customer. This information will also be collected for existing legal entity customers who establish accounts.

We acknowledge the sensitivity of the requested personal information but must obtain it to comply with legal requirements. 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

Here are the highlights for you to understand about Beneficial Ownership

• The regulation impacts all legal entities opening or maintaining accounts at any financial institution.
• Legal entities must identify and attest to ultimate beneficial owners who meet specific requirements and a controlling person. This includes top executives like CEO, CFO, COO, Managing Member, General Partner, President, VP, or Treasurer.
• Dime Community Bank collects information on ultimate beneficial owners and control persons of legal entities. The collection is done regardless of a personal relationship with the Bank.

Beneficial Ownership FAQ

What is the beneficial ownership regulation and why does it matter?

The beneficial ownership regulation is a federal law requiring financial institutions to identify and verify the identity of beneficial owners. They must also identify the controlling person of the legal entity when opening or maintaining an account. The regulation is aimed at making financial institutions safer for their customers and protecting the country’s financial system.

Why has Dime Community Bank been asked to collect this information?

Dime, 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. Dime is doing its part in upholding the new regulation to protect the financial system. Dime prioritizes compliance with regulations, including the new beneficial ownership regulation, which receives equal importance and attention.

Is Dime Community Bank the only bank that is required to collect beneficial ownership information?

No. All financial institutions must comply with new beneficial ownership regulations and collect such information from relevant customers.

What constitutes beneficial ownership?

“Beneficial ownership” under U.S. government regulation includes two roles: (1) owners of a legal entity and (2) controllers of a legal entity.

Dime is required to identify and collect personal information for individuals with an ownership interest in the legal entity. This applies to those who meet or exceed the following ownership thresholds:

Ultimate Beneficial Owners: A natural person having 25 percent or more of the equity interests of a legal entity.

Control Person: A person in charge of a legal entity customer wields substantial managerial control or influence (e.g., CEO, CFO, COO, Managing Member, General Partner, President, VP, Treasurer).

For every legal entity client subject to beneficial ownership, you must identify one control person. 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, your Dime representative may request beneficial ownership information to update your account file, ensuring compliance with future financial requests.

What if the identified beneficial owners or control persons are not Dime Community Bank clients? Do I still need to provide their personal information to Dime Community Bank?

Yes. To comply with the regulation, regardless of customer status, you must provide information on the ultimate beneficial owners and control person.

My Dime Community Bank 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 Dime must collect from legal entity customers. It pertains to their ultimate beneficial owners and control person. By completing the form, you are attesting that the information provided is accurate to the best of your knowledge.

Where will Dime Community Bank store beneficial ownership information?

Dime 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 without a Dime Community Bank relationship?

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

I also have personal accounts with Dime Community Bank. Will beneficial ownership information be collected for my personal accounts?

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