To complete the M&T Bank beneficial ownership form, you list every individual who owns 25 percent or more of your business, plus one person who controls day-to-day operations, provide each person’s name, date of birth, address, and ID number, and hand the signed form with a copy of each listed person’s government photo ID to your M&T representative. The bank cannot open your business account until this form is on file.
Does Your Business Have to Complete It
Federal rules require the form for any “legal entity customer” opening an account: corporations, LLCs, general partnerships, and other entities formed by filing with a Secretary of State or a similar office, including foreign entities opening a U.S. account.1eCFR. 31 CFR 1010.230 – Beneficial Ownership Requirements for Legal Entity Customers Sole proprietorships and most private trusts are not legal entities under the rule and do not complete the form. A statutory trust formed by state filing is the exception and does need one.2Federal Register. Customer Due Diligence Requirements for Financial Institutions
A short list of already-regulated entities is exempt — publicly traded companies, banks and bank holding companies, SEC- or CFTC-registered firms, state-regulated insurers, and a handful of others.3eCFR. 31 CFR 1010.230 – Beneficial Ownership Requirements for Legal Entity Customers If you think your entity qualifies, tell the M&T representative up front so they can document the exemption instead of running you through the full form.
Who Goes on the Form
Two separate tests apply, and both run at the same time.
Ownership: Anyone at 25% or More
List every individual who directly or indirectly owns 25 percent or more of the equity in the entity. That can be zero people if ownership is split finely enough, or up to four.3eCFR. 31 CFR 1010.230 – Beneficial Ownership Requirements for Legal Entity Customers Indirect ownership counts: if someone holds their stake through a parent company or a contract, they still belong on the form. When a trust holds 25 percent or more, the bank looks through to the trustee.4FinCEN.gov. CDD Rule FAQs
Control: Exactly One Manager
You always list one individual with significant management responsibility, regardless of what happens with the ownership section. That is typically a CEO, CFO, COO, president, managing member, general partner, or treasurer, or anyone who regularly performs equivalent functions.1eCFR. 31 CFR 1010.230 – Beneficial Ownership Requirements for Legal Entity Customers If a single owner runs the company, that person gets listed under both prongs. Total names on the form range from one (a solo owner-operator) to five (four 25 percent owners plus a separate control person).
What to Collect Before You Sit Down
For every individual you will list, gather:
- Full legal name, spelled exactly as it appears on their government ID
- Date of birth
- Residential or business street address — no P.O. boxes
- Social Security number for U.S. citizens and residents, or a passport number or other government-issued ID number for non-U.S. persons
- A copy of a current government-issued photo ID, such as a driver’s license or passport; photocopies are acceptable
The address requirement is the most common stumbling point. It has to be a physical location.1eCFR. 31 CFR 1010.230 – Beneficial Ownership Requirements for Legal Entity Customers A home address is fine for someone who works from home.
Bring your business formation documents too. M&T uses articles of incorporation, an operating agreement, or a partnership agreement to confirm the structure and the ownership percentages you disclose.5M&T Bank. Small Business Checking Accounts
Filling It Out and Signing
M&T may hand you its own version of the form or the standard template from Appendix A of 31 CFR § 1010.230. The person opening the account fills it in and certifies the information to the best of their knowledge; they do not have to be one of the beneficial owners themselves.3eCFR. 31 CFR 1010.230 – Beneficial Ownership Requirements for Legal Entity Customers The certification is not a formality. Knowingly providing false information on a form used by a federally regulated bank can be prosecuted under 18 U.S.C. § 1001, which carries up to five years in prison.6Office of the Law Revision Counsel. 18 USC 1001 – Statements or Entries Generally
The layout is straightforward: one section for the entity, one section per beneficial owner. Match names to the photo ID exactly, including middle names and suffixes. Small discrepancies are the most common reason banks send a form back.
Submitting the Form to M&T
The simplest route is a branch visit. Hand the completed form and copies of each listed person’s photo ID to your M&T representative, who can review it on the spot and flag anything missing before it enters the system. If you are opening the account remotely, the bank may provide a secure upload link through its commercial banking platform; ask your representative for the specific URL.
Once M&T has the form, it cross-references what you provided against public records and internal databases. If something does not match — a name spelled differently on a state filing, for instance — a representative will contact the primary account holder to sort it out. Verification typically wraps up within a few business days. Multi-layer ownership structures can take longer.
Keeping the Information Current
There is no annual re-certification. The bank updates beneficial ownership information on a risk basis when it becomes aware, through transaction monitoring, a loan review, a change in signers, or a conversation with you, that ownership may have shifted. If a co-owner sells their stake and a new investor comes in above 25 percent, expect the bank to ask for a fresh form. Telling M&T proactively is easier than having the account flagged for review at an awkward time. New beneficial owners have to be identified, certified, and verified the same way as at account opening.4FinCEN.gov. CDD Rule FAQs
This Is Not the FinCEN BOI Report
M&T’s beneficial ownership form and the Beneficial Ownership Information (BOI) report that the Corporate Transparency Act required companies to file directly with FinCEN are two separate obligations. The bank form stays with M&T and is never forwarded to FinCEN.
As of March 2025, FinCEN issued an interim final rule exempting all U.S.-formed entities and their U.S.-person beneficial owners from the CTA’s direct reporting requirement.7FinCEN.gov. Beneficial Ownership Information Reporting Only foreign entities registered to do business in a U.S. state still file BOI reports with FinCEN. That exemption changes nothing at the bank level. M&T still collects the beneficial ownership form under 31 CFR § 1010.230 whenever you open a business account, whether or not your entity has any FinCEN filing obligation.