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A customer has two houses in different states. Does the address listed on his license need to match the address on his beneficial ownership form?

An outside auditor has cited my bank for the following: The bank has a customer who has two homes, one in Oregon and one in California. The Oregon address is his legal residence and the address listed on his driver’s license. This customer recently took out a commercial loan for one of his California businesses and used his California address (which is also the business address) on the loan documentation. In applying the bank’s customer identification policy (CIP) and identifying him as the sole beneficial owner, the bank used his Oregon address on the beneficial ownership form. The auditor indicated that the addresses on the beneficial ownership form and driver’s license must match the address on the loan documents and cited the bank for a Bank Secrecy Act (BSA) violation.

It appears that the auditor is in error, as the address of a beneficial owner, even if he is the sole owner, may be either the individual’s residential or the business address. (See 31 CFR 1010.220(a)(2)(i)(3).)

There is nothing in the law requiring that the address on the license to match the address of the business. In fact, it would be unusual for a driver’s license address to match a business address. You should ask the auditor the basis for the criticism and then point out this regulatory provision. (February 2021)

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