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Introduction

A Customer record in Lead’s platform represents a legal entity or organization and defines its rights and roles related to our products. You must create a Customer record for each of your end users in order to provision Lending, Depository, and Card products or to generate account numbers.
Each day, submit a Customer file containing all new customer records created the previous day, along with any updates to existing records. Do not include records that have not changed.

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Customer Types

  • Individual: For individual persons.
  • Business: For businesses (excluding sole proprietorships). Requires details on beneficial owners and control persons.
  • Sole Proprietorship: For sole proprietorships. Exempt from beneficial ownership requirements.

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Example

Customer data requirements vary by the customer’s role in relation to Lead products. For example, consider Pete’s Pizza. Pete’s Pizza is an LLC business owned by Pete, a control person, and his wife Amanda, a beneficial owner. Pete’s sister, Sam, is an authorized signer on the business checking account and Daisy, Pete’s employee, is an authorized debit card user with restricted access on the business account.
EntityRoleCreated As
Pete

(owner of Pete’s Pizza LLC)		control personAn individual customer with full KYC details: name date of birth, contact info, physical address, and government verified ID.
Amanda

(Pete’s wife)		beneficial ownerAn individual customer with full KYC details.
Pete’s Pizza-A business customer with full KYB, your risk assessment on the business, and Pete and Amanda listed as the control person and beneficial owner.
Sam

(Pete’s sister)		authorized signerAn individual customer with full KYC details and later associated with the business checking account.
Daisy

(employee)		authorized signerAn individual customer with partial KYC details (name and contact info).

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Customer Type Examples

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Individual Customers

For end customers who are individuals:
  1. Create individual customers (customer_type = individual) for the intended roles of authorized_user, authorized_signer, and/or account_holder.
    • Typically, the individual is the account holder.
    • Use authorized_user or authorized_signer roles when the person is not the legal account holder but requires limited access.

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Business Customers

For businesses (excluding sole proprietorships), we expect at least one control person and all beneficial owners.
  1. Create individual customers(customer_type = individual) for beneficial owners and control persons.
    • Data requirements for beneficial owners/control persons match those of authorized_signer roles.
  2. Create business customers(customer_type = business) as account_holders.
    Steps 1 and 2 can be created in any order
    On the same day, 1 before 2, 2 before 1 on the same day, or on different days. However, the business customer won’t validate until the association is made in step 3.
  3. Associate the relationship of individual customers (from step 1) to business customers (step 2) under ‘Customer Relationship.‘

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Beneficial Ownership Requirements

Lead requires customers to send Beneficial Ownership information that is in line with the CIP program reviewed by Lead Bank during Due Diligence. At a minimum, this should include all Beneficial Owners with ownership percentages 25% or greater. If your KYB process expressly states a lower percent than 25% then all beneficial owners who meet your expressly stated percentage must be required.
All Beneficial Owners must reduce to an individual. If a beneficial owner is a Business Entity, then the same requirement applies to the beneficial owners of that Business Entity.
Example
  • Create Alan (beneficial owner), Bob (control person), and Charlie (authorized user) as individual customers (intended_roles = authorized_signer).
  • Create Bob’s Pizza Company as a business customer (intended_roles = account_holder).
  • Assign Alan and Bob’s client_customer_id to Bobs’ Pizza Company business client_customer_id via ‘customer relationship’.
  • Charlie, as an authorized user, does not need to be linked to the business customer.

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Sole Proprietorship Customers

For sole proprietorships (exempt from beneficial ownership requirements):
  1. Create individual customers (customer_type = individual) for sole proprietors.
    • Data requirements for sole proprietors match those of authorized_signer roles.
  2. Create a sole prop customer (customer_type = sole_prop) as the account_holder.
    Steps 1 and 2 can be created in any orderOn the same day, 1 before 2, 2 before 1 on the same day, or on different days. However, the sole prop customer won’t validate until the association is made in step 3.
  3. Associate the relationship of individual customers (from step 1) to sole prop customer (step 2) under ‘customer relationship.’
Example
  • Create Daniel as an individual customer (intended_roles = authorized_signer).
  • Create Daniel’s Dry Cleaning as a sole_prop customer (intended_role = account_holder).
  • Assign Daniel’s client_customer_id to his Dry Cleaning business client_customer_id via ‘customer_relationship.‘

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Customer Roles

Customer roles indicate requirements for when a customer record will be provisioned a financial product by Lead with the Account Holder, Authorized Signer, or Authorized User roles.
Customer roles follow the same pattern and hold the same data requirements as Entity Roles.