Verifying Annual State Filings Are Up to Date

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Question:

During account opening for a new business customer the branches verify that the required annual filings with the state are up to date. As new accounts are opened for existing business customers a CDD questionnaire is completed for each new account, however the branches are pushing back regarding verifying that annual state filings are up to date. I haven't been able to locate any guidance on whether this is a requirement or a recommended best practice. Can you please advise?

Answer:

It's a recommended best practice. Banks do it because an entity that is delinquent in its required state filings may (depending on state law) no longer be "in good standing" and may eventually legally dissolved if the filings are not brought current.