How do I complete the Supplemental Institutional Account Application for an Entity?

If you are opening a Prime Trust Institutional Account, you will need to complete the Supplemental Institutional Account Application before we can complete the setup of your account.

The information you provide will be used by Prime Trust to comply with its regulatory obligations for KYC and AML, so we ask that you carefully complete the form by following the steps below.  Providing incorrect information can prevent your account from being approved. In this article, we'll try to make completing this form as easy as possible by walking you through the steps and outlining the documents you'll need to upload. 

STEP 1

Provide Company Information 

As an "Entity" account, we will need the following:

1. A copy of the company’s official formation or organizational document,
   such as the articles of incorporation, certificate of formation, partnership
   agreement, by-laws, operating agreement or trust instrument, as
   applicable;
2. Address verification (mail item dated within the last 90 days that lists the
   company Name and the address provided)
3. Proof of beneficial ownership of the company evidencing those entities or
   individuals owning 25% or more.  To fulfill this requirement, you can submit an operating agreement, partnership agreement, share registry, capitalization table, or Schedule K1.

STEP 2

Provide Documentation for Beneficial Owners (Individual) Or Control Persons

We will need the following:

1. If any individual owns 25% or has rights to own, please complete the Beneficial Ownership (individual) form. 
2. Provide a copy of a valid government issued ID (driver’s license or passport) for EACH Beneficial Owner.
3. Address verification (mail item dated within the last 90 days that lists the individual
   and the address provided).

For your reference, the Beneficial Ownership (Individual) Document will look like the image below. All fields within the document must be completed. If something does not apply, please enter N/A into the appropriate field. This document can be found here or by scrolling through the Onboarding Application provided in your account.

STEP 3

Provide Documentation for Beneficial Owners (Entity) or General Partner/Investment Manager 

In Step 2, you provided the documentation for the Individual Beneficial Owners. Now, we'll need documentation for the Entity Beneficial Owners. (**IS THIS CORRECT TO SAY?)

If any entity owns 25% or more, please complete the Beneficial Ownership (Entity) form and send the following:

1. A copy of the company’s official formation or organizational document, such as the articles of incorporation, certificate of formation, a government issued business license, a partnership agreement, offering memorandum or trust instrument, as applicable.
2. Address verification (mail item within the last 90 days that lists the individual and the address provided) if address is not listed on ID.
3. Proof of beneficial ownership of the company evidencing those entities or individuals owning 25% or more, such as an operating agreement, partnership agreement, share registry, capitalization table, or Schedule K 1.
4. If any individual owns, or has the rights to own, 25% of more of the entity please complete the individual beneficial owners of entity beneficial owners section & provide the following for each beneficial owner:
   • A copy of valid government issued ID (passport/visa/driver’s license).
   • Address verification (mail item within the last 90 days that lists the individual and the address provided) if address is not listed on ID.

For your reference, the Beneficial Ownership (Individual) form will look like the image below.  All fields within the document must be completed. If something does not apply, please enter N/A into the appropriate field. This document can be found in the Onboarding Application or by clicking here.

Who is considered a Beneficial Owner and how do I know who to include?

FinCen defines a Beneficial Owner as:

1. Each individual, if any, who, directly or indirectly, owns 25% or more of the equity interests of a legal entity customer (i.e., the ownership prong); and
2. A single individual with significant responsibility to control, manage, or direct a legal entity customer, including an executive officer or senior manager (e.g., a Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President, or Treasurer); or any other individual who regularly performs similar functions (i.e., the control prong).

For example, based on the diagram below, Allan is a beneficial owner of "Customer" because he indirectly owns 30 percent of its equity interests through his direct ownership of Company A. Betty is also a beneficial owner of "Customer" because she indirectly owns 20 percent of its equity interests through her direct ownership of Company A plus 16⅔ percent through Company B for a total of indirect ownership interest of 36⅔ percent. Neither Carl nor Diane is a beneficial owner because each owns indirectly only 16⅔ percent of Customer’s equity interests through their direct ownership of Company B.

STEP 4

Complete and submit all required forms

There are several required forms that will need to be completed and submitted in addition to the documentation outlined above. These forms include:

1. Business Activity Information 
2. Account Signatory Authority 
3. Beneficial Owners (Individual)
4. Beneficial Owners (Entity) - If Applicable
5. Individual Beneficial Owners of Entity Beneficial Owners - If Applicable

All forms are provided in the Supplemental Institutional Account Application.  When filling out each form, do not leave any boxes blank. If a section does not apply to you, simply enter N/A in the corresponding box. 

STEP 5

Confirmation, Signature & Submission

On the last page of the Supplemental Institutional Account Application, review the Account Authorization Agreement and provide your signature.   A first and last name is required in the "Name (Print)" and the "Signature" box. 

Due to the confidential personal information contained in the Application, it must only be submitted to Prime Trust, LLC using our online portal.  To submit your application, merge all of the required documents and completed forms into a PDF and upload it to your Prime Trust account via the secure link. This link will be located in the "Upload Documents" section of your account (as shown below).  

Once you have uploaded the Application and supporting documentation, please send an email to compliance@primetrust.com notifying our Compliance Department.

If you have any questions or concerns while completing this Application, please reach out to us at compliance@primetrust.com.