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Signed Reg GG Disclosure - Entity or Account Specific?

Answered by: 
Randy Carey

Question: 
Is a Reg GG Disclosure that a customer signs meant to be entity specific or account specific? If Joe's Autos opens 4 accounts, do we need 4 Reg GG disclosures signed or will one work since the verbiage states "this entity does not engage in internet gambling.."?
Answer: 

by Randy Carey:

First of all, there are no Reg. GG disclosures, so I'm not sure what you are referring too. Are you talking about some sort of certification signed by the borrower? That too is not required unless a bank cannot determine that the customer presents minimal risk of engaging in an Internet gambling business.

Answer: 

by Ken Golliher:

There are no "model" forms for obtaining a customer's certification that it is not involved in illegal Internet gambling. Accordingly, no one here knows what your internal form says; i.e. whether it is for the entity or for one of the entity's accounts. A form could be worded in such a way that a customer says they are not currently involved in Internet gambling and that they agree to inform your bank if that should ever change...

First published on 08/27/2017

Filed under: 
Compliance
Filed under compliance as: 
Reg. GG
Internet Gambling

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