TPA - Beneficial Ownership Requirement (Public vs Private)

Any entity that is publicly traded on US exchanges would be exempt from the beneficial ownership requirements. Via the TPA, the ticker entered will cause the system to bypass the beneficial ownership section.

Below screenshot from Pathward’s ‘BSA Compliance Program Guideline for Partners’ references the same, that the business must be publicly traded on NYSE or NASDAQ in order to be exempt from providing beneficial ownership:

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Now, if you have an entity that is not publicly traded and Beneficial Owner is another entity, you would have to collect BO on that second entity. So for example: a TPA for ABC Ice Cream and their beneficial owner is Abby’s Creamery, the requirement would be to collect BO on Abby’s Creamery…When entering a business as the ‘primary’ BO, the TPA will force you to get the second entity’s BO information. Screenshot below of how it looks in the TPA.

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