Business Accounts

Credit unions may offer any type of share account for business purposes. To open a business account or use other credit union services, an authorized representative of the business (or other legal entity) must qualify for the credit union’s field of membership.

Credit unions that offer business accounts must comply with all applicable laws and regulations, such as Availability of Funds and Collection of Checks (Regulation CC), and the BSA. For more information, see NCUA regulation § 748.2, Procedures for monitoring Bank Secrecy Act (BSA) compliance.

NCUA regulation § 745.6, Accounts held by a corporation, partnership, or unincorporated association, defines share insurance coverage provisions for business accounts. Coverage for business accounts is different from consumer share account coverage and government share account coverage. The NCUA prohibits individuals from opening a business account for the sole purpose of increasing share insurance coverage.

To offer business accounts, a credit union may need to establish additional policies, procedures, and internal controls to monitor and manage these accounts appropriately.

Due Diligence

Credit unions that offer business accounts must establish clear policies, procedures, and controls around these accounts as established in Treasury regulation § 1010.230, Beneficial ownership requirements for legal entity customers. Business accounts are subject to BSA, which requires a credit union to obtain and verify the identification of beneficial owner(s) of companies opening a new account after May 11, 2018. Credit unions may use a certification form or other documentation method to certify, at minimum, the name, date of birth, address, and identification number of each beneficial owner.

To manage business accounts in a safe and sound manner, a credit union should also perform the following steps when opening an account.

  • Obtain and review:

    • Signature card

    • Articles of Incorporation, if applicable

    • Partnership Agreement, if applicable

    • Financial statements

    • Corporate resolutions

    • Operating agreement

  • Confirm the business has a state/local license to operate

  • Confirm the business’ EIN as required by the IRS (see the FFIEC BSA/AML Examination Manual)

  • Confirm that MSBs have registered with FinCEN, as required by CFBP regulation § 1022.380, Registration of money services businesses

  • Confirm the business’s compliance with FRB regulation part 233, Prohibition on Funding of Unlawful Internet Gambling (Regulation GG), as applicable

  • Perform a risk assessment to understand the nature and purpose of the member relationship and to identify higher risk accounts

    • Credit unions may need to perform ongoing risk assessments of higher risk accounts and cash-intensive businesses (such as, MSBs and MRBs)

Refer to the Bank Secrecy Act section of the Examiner’s Guide and the Business Entities (Domestic and Foreign) – Overview section of the FFIEC BSA/AML Examination Manual for more information on business accounts.

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