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Important Information Regarding Business Accounts

Overview

In May 2016, the U.S. government passed a new regulation regarding the beneficial ownership of legal entity business customers. Going forward, it will be mandatory for all financial institutions to comply with this regulation by identifying the ultimate beneficial owner(s) and a controlling person of a legal entity customer opening or maintaining an account.

In compliance with this new regulation, Partners Bank of California will collect beneficial ownership information from legal entity customers starting in the second quarter of 2018. This means that any time an account is opened or maintained for a legal entity, we will request information that identifies the ultimate beneficial owner(s) and controlling person of the legal entity. The required identifying information includes name, address, date of birth, identification number, and other information that will help identify those individuals. This information will need to be collected whether or not the person identified is a Partners Bank of California client. This information will also be collected for existing legal entity customers who establish or maintain accounts once this new regulation is implemented at Partners Bank of California in the second quarter of 2018.

While we understand the information requested is personal and sensitive, we need to obtain this information in order to comply with the law. As always, all information will be stored securely and handled with the same standard of privacy that we have always maintained.

What you need to know about Beneficial Ownership

  1.  The new regulation impacts all legal entities opening or maintaining accounts at any financial institution;
  2.  Legal entities will need to identify and attest to all ultimate beneficial owner(s) that meet specific requirements as well
     as a controlling person (e.g., Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member,
     General Partner, President, Vice President or Treasurer);
  3.  Partners Bank of California will collect information regarding the ultimate beneficial owner(s) and control person of legal entities whether or not they have a personal relationship with the financial institution.

Frequently Asked Questions about Beneficial Ownership Information

1. What is the beneficial ownership regulation and why does it matter?

The beneficial ownership regulation is a federal law requiring all financial institutions to identify and verify the identity of
the beneficial owners of legal entity customers as well as a controlling person of the legal entity anytime an account is
opened or maintained. The regulation is aimed at making financial institutions safer for their customers and protecting the
country’s financial system.

2. Why has Partners Bank of California been asked to collect this information?

Partners Bank of California, as well as all other financial institutions in the U.S., will be required to collect beneficial ownership
information. The U.S. government implemented the new beneficial ownership regulation to help fight financial crimes.
Partners Bank of California is doing its part in upholding the new regulation to protect the financial system. Compliance with
regulations has always been of utmost importance to Partners Bank of California, and the new beneficial ownership regulation
will be treated with the same level of importance.

3. Is Partners Bank of California the only bank that is required to collect beneficial ownership information?

No. All financial institutions are required to comply with the new beneficial ownership regulation and will be collecting this
beneficial ownership information from applicable customers.

4. What constitutes beneficial ownership?

The U.S. government regulation defines “beneficial ownership” as being made up of two roles: (1) those that have an
ownership interest in a legal entity and (2) those that control a legal entity.

For those people who have an ownership interest in the legal entity, Partners Bank of California is required to identify and collect personal information on anyone that meets or exceeds the following ownership threshold and controlling interest in the legal entity:

A. Ultimate Beneficial Owners:
A natural person having 25 percent or more of the equity interests of a legal entity.

B. Control Person:
A person with significant managerial control or influence over a legal entity customer (e.g., Chief Executive Officer, Chief
Financial Officer, Managing Member, General Partner, etc.) For every legal entity client subject to beneficial ownership, you
must identify one control person.

NOTE: It is possible that the control person may also be an ultimate beneficial owner.

5. How will the change impact my existing accounts?

The change should not impact your existing accounts. However, please be aware that your Partners Bank of California
associate may reach out for beneficial ownership information to update your account file, ensuring necessary compliance
for any future financial requests.

6. What if the people who have been identified as beneficial owners or control persons are not clients of Partners Bank
of California? Do I still need to provide their personal information to Partners Bank of California?

Yes. Regardless of customer status, information about the ultimate beneficial owners and control person must be provided
in order to comply with the regulation.

7. My Partners Bank of California representative has asked me for a Certification of Beneficial Ownership. What is this
and why is it necessary?

The Certification of Beneficial Ownership is a legally required form that Partners Bank of California must collect from legal
entity customers regarding their ultimate beneficial owners and the control person. By completing the form, you are attesting
that the information provided is accurate to the best of your knowledge.

8. Where will beneficial ownership data be stored?

Partners Bank of California will maintain beneficial ownership information in its system of record. We maintain strict privacy
policies and procedures. Any client information, including beneficial ownership information, will not be shared.

9. Will the information I provide for beneficial ownership be used for marketing to prospects that do not already have
a relationship with Partners Bank of California?

No. This information will not be used for marketing or prospecting purposes.

10. How do I get beneficial ownership information back to my Partners Bank of California representative?

Beneficial ownership information will be collected using Partners Bank of California documents and should be returned to
your Partners Bank of California associate.

11. Given the sensitive nature of the information that is being provided for beneficial ownership, can I provide the
details directly to my Partners Bank of California associate?

Yes. If you are more comfortable providing information in person, please reach out to your Partners Bank of California
representative directly.

12. I also have personal accounts with Partners Bank of California. Will Partners Bank of California also collect beneficial
ownership information for my personal accounts?

No. The Beneficial Ownership regulation only applies to applicable legal entity accounts.


If you have any questions or need additional information about business account ownership information
or any of our products and services at Partners Bank of California, please give us a call or email at:
(949) 732-4000 • information@partnersbankca.com