Frequently Asked Questions -

Beneficial Ownership/New Merchant Applications Who is a Beneficial Owner? As defined in the rule, a Beneficial Owner is:  Any individual who directly or indirectly own 25% or more of the legal entity  One individual with significant responsibility to control, manage, or direct the legal entity (e.g., Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Managing Member, General Partner, President, Vice President, or Treasurer) What is the new Beneficial Ownership requirement? For new accounts that are not exempt, Vantiv, now Worldpay will be required to collect the name, address, date of birth, and social security number of one Control Owner AND each of the four data points for up to four Beneficial Owners as defined above. If the new account is not exempt AND is considered High Risk, then we have to collect the name, address, date of birth, and social security number for one Control Owner AND each of the four data points for up to 10 Beneficial Owners (anyone with 10% or more legal ownership). Who is not exempt / exempt? Not Exempt Exempt Limited Liability Corporation (LLC) Unincorporated Association Partnership (General or Limited) Government-Federal/State/Local Private Corporation Individual/Sole Proprietor Trust (if created by state filing) Regulated Financial Institution Publicly Traded Corporation (on a U.S. stock exchange) Trust (if not created by state filing) SEC Registered (i.e. Inv. Advisor/Co, exchange/clearing) What about nonprofit corporations and similar nonprofit entities? Nonprofits are unique in that they are exempt from the 25%/10% ownership portion of the rule, but still must provide the four data points for one Control Owner. What if the Control Owner/Beneficial Owner does not have a social security number? Beneficial Owners/Control Owners who do not have a social security number (or ITIN) issued by the United States must provide a national ID (i.e. pass vzdzcz www.vantiv.com What if the Control Owner/Beneficial Owner does not want to provide the social security number? The Federal requirement does not allow for provision of alternate identification for those who have a US national ID issued. If they have a US-issued national ID, residents must provide it. Otherwise, the account will not pass subsequent checks and Worldpay will not be able to open the merchant processing account. Who is a Control Owner? A Control Owner is an individual with significant responsibility to control, manage, or direct a legal entity customer, such as 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 individual who regularly performs similar functions. Are credit checks conducted on Beneficial Owners? Credit checks are conducted on the Guarantors. If a Control Owner/Beneficial Owner is also a Guarantor, then the credit check is conducted on them in that capacity. Will the Control Owner/Beneficial Owner need to sign the contract? No. Only the collection of the information is required. What do we do with the information? Besides collecting the information, we will perform a sanctions check to ensure we can do business with the entity. We will also utilize the information in ongoing Regulatory Compliance reviews of the entity. Who is considered High Risk?* The below businesses are considered High Risk. If they are not exempt, we will have to collect the name, address, date of birth, and social security number for one Control Owner AND each of the four data points for up to 10 Beneficial Owners (anyone with 10% or more legal ownership). *please note that this list is subject to change Adult Entertainment, Adult Clubs, Sexual Aids/Toys Auto Dealerships, new and used when accepting loan payments B to B Debt Repayment Consumer Financing Crowdfunding Cyberlockers Dating Services Digital Wallet or Prepaid Card Companies Foreign Exchange Trading Firearms Card Not Present Investment Firms including Brokers and Dealers Gambling and Gaming, including Sports Forecasting & Odds Making, DFS Multi-Level Marketing Money Service Business vzdzcz www.vantiv.com Not For Profit Credit Repair/Counseling Services Negative option subscription enrollment/high risk business type Payment for Uncollectable Bad Debt Nutraceuticals Card Not Present Pharmaceutical Card Not Present Penny Auctions Sweepstakes Script Dispensing Terminal Tribal Entities Tech/IT Support Providers Wealth Building/Business Opportunities Virtual Currency (using a card to fund a VC account – pending sponsor bank)