Just curious if most are including account number(s) on the beneficial ownership certification form or using the entity's tax ID number to identify. Some forms have this as an optional field.

Our software automatically includes the account number on the form.

That would be nice.

We formatted our form to include the account number.

Account number may be included, but not required.

We are listing the account number.

Our forms vendor has not yet put the account number on, but we are hoping that will be coming. Right now, just the EIN.

We include the acct number on our form to show proof of ben owner compliance during the trigger event (new account)

Acct number

As "R" said, we include to demonstrate that the form was obtained in connection with a triggering event -- a new account. If you have a customer that opens numerous accounts (we have many), how will you prove that you met the requirement for a particular account?

We are using account number also.

So you open an account for XYZ, Inc. on 07/01 and you get BO information. On 08/01 you open another account for the same company and get BO information. So, if the ownership of XYZ, Inc. changed between 08/01 and 07/01 - how do you reconcile that with the information you have on file for the first account?

Our form also has a place for the account number. The forms are stored under the entity's EIN. So our stance is that the most recent signed form on file for that EIN trumps the others.

our vendor forms include account number field. if multiple accounts are opened at same time we are simply writing the additional account numbers on the same form. the EIN field is also populated in

I agree with Justin Case. I believe this was FinCEN's intention. The most recent CBO is supposed to have current information regarding beneficial owners. Each time you open a new account it's an opportunity to make sure the information is correct.

Note, that I don't agree with all this...... it's just what I think they intended.