Good Afternoon folks. We are reviewing our procedures and a good question came up about Beneficial Ownership. We have noticed some Social Organizations are filing as Trade Names for clubs and leagues assocaited with the organzation. An Examples would be John Doe Lodge (Main Social Organization which is not registered with the State of Ohio) and John Doe Lodge Bowling League (Trade Name registered with the State of Ohio). Both are Non-Profit groups however only the Trade Name is registered. Would we need the Beneficial Ownership and registration of the Lodge for a League account or do we just do the Trade Name layer and treat it as a DBA and not obtain anything further from the 'parent' organization? Does the 'parent' organization need to be registered with the State of Ohio as well as the League? I Have tried reading through the rule and since it seems Trade Name is a State of Ohio type item I cannot find anthing in the rule for it. Any thoughts or guidence on where I can research this is much appreciated.

Don't expand your definition of legal entity customer beyond the FinCEN definition. From 31 CFR 1010.230(e)(1):

Legal entity customer means a corporation, limited liability company, or other entity that is created by the filing of a public document with a Secretary of State or similar office, a general partnership, and any similar entity formed under the laws of a foreign jurisdiction that opens an account.

The social organizations, if not incorporated as described in that definition, are not legal entity customers, and registering a trade name with the SOS does not create a legal entity.

Registration of a trade name does not make these organizations subject to the beneficial ownership rule.

Thank you so very much John. That was the pathway I was going to but I just wanted to be sure the squirrels in my head were thinking correctly.