Private lenders run recurring questions on the identity-verification framework against the loan-boarding cycle. This article answers the questions on the Customer Identification Program framework, the FinCEN Beneficial Ownership framework, the OFAC sanctions-screening framework, the taxpayer-identification-number framework, and the entity-authority-documentation framework.

What is the Customer Identification Program framework?

The Customer Identification Program framework runs the identity-verification framework under the USA PATRIOT Act §326 framework against the Bank Secrecy Act framework. The framework runs four data elements against each natural-person borrower — full legal name, residential address, date of birth, and taxpayer-identification-number framework — and runs the verification framework against a government-issued photo-identification document framework on the standard.

What is the FinCEN Beneficial Ownership rule?

The FinCEN Beneficial Ownership Information rule runs the beneficial-ownership-reporting framework under the Corporate Transparency Act framework. The rule runs the verification framework against each natural-person beneficial owner on the substantial-control framework or the ownership-interest framework above the FinCEN-defined ownership threshold. The rule runs the BOI report framework against the FinCEN framework on the entity-formation cycle and on the beneficial-ownership-change cycle.

What is OFAC sanctions screening?

OFAC sanctions screening runs the Office of Foreign Assets Control framework against the Specially Designated Nationals and Blocked Persons List on each borrower, each entity, and each beneficial owner. The framework runs the screening framework against the consolidated-sanctions-list framework at the loan-boarding cycle, runs against the wire-transfer cycle, and runs against the borrower-payment cycle on the recurring framework.

What is IRS TIN matching?

IRS TIN matching runs the taxpayer-identification-number verification framework against the IRS framework. The framework runs the borrower’s name and taxpayer-identification number against the IRS framework on the TIN-matching framework. The framework runs the IRS Form 1098 reporting framework against the IRS framework on the year-end cycle without a backup-withholding event when the TIN-matching framework runs clean.

What is the entity-authority-documentation framework?

The entity-authority-documentation framework runs the signer-authority verification framework against the entity borrower on the loan-boarding cycle. The framework runs against the limited liability company, corporation, limited partnership, and trust frameworks. The framework runs the formation-document framework, the governance-document framework, and the signer-authorization-resolution framework against the signer-authority cycle.

What documents run the identity-verification framework?

The identity-verification framework runs against ten document categories on each new loan — borrower identification, entity formation, entity governance, signer authority, FinCEN BOI, OFAC screening, Form W-9 or Form W-8BEN, IRS TIN matching, address verification, and the audit-trail framework on the lender’s servicing platform.

What is the audit-trail framework?

The audit-trail framework runs the verification-recordkeeping framework against the loan-boarding cycle. The framework runs the verification-document framework, the verification-method framework, the verification-date framework, the verification-officer framework, and the exception-and-escalation framework against the lender’s servicing platform on the regulatory-retention cycle.

What is the Form W-9 framework?

The Form W-9 framework runs the taxpayer-identification-number framework against the United States borrower on the IRS framework. The framework runs the borrower’s name, the taxpayer-identification number, and the certification framework against the IRS Form 1098 reporting framework on the year-end cycle. The framework runs the backup-withholding framework against the borrower on a TIN-matching-failure cycle.

Related Topics

• Identity Verification at Loan Boarding
• Five Wire Fraud Defenses for Private Lenders
• Mortgage Fund Subservicing Done Right
• Multi-Lender Notes With Up to 10 Investors
• Fidelity Bonds for Trust Account Signatories

This article is educational and does not constitute legal, regulatory, or tax advice. The identity-verification framework runs against the Bank Secrecy Act framework. The framework runs against the USA PATRIOT Act §326 Customer Identification Program framework. The framework runs against the Corporate Transparency Act beneficial-ownership framework. The framework runs against the OFAC sanctions-screening framework and the IRS framework on the lender’s recurring compliance cycle. Consult qualified legal counsel and a tax adviser on the specific identity-verification framework against any private-lending operation.

Sources

• USA PATRIOT Act §326 — Customer Identification Program. Financial Crimes Enforcement Network.
• FinCEN Beneficial Ownership Information Reporting Rule. Financial Crimes Enforcement Network.
• Office of Foreign Assets Control — Specially Designated Nationals List. U.S. Department of the Treasury.
• IRS TIN Matching Program. Internal Revenue Service.
• FFIEC Bank Secrecy Act / Anti-Money Laundering Examination Manual. Federal Financial Institutions Examination Council.