> ## Documentation Index
> Fetch the complete documentation index at: https://docs.lead.bank/llms.txt
> Use this file to discover all available pages before exploring further.

# Beneficial Ownership Requirements

> Which beneficial owners and control persons Lead requires for business entities, the 25% threshold, and the drill-down rule for indirect ownership through holding companies.

Business entities must arrive with their ownership structure resolved to **natural persons**. This page covers who must be reported, at what threshold, and how to handle ownership through intermediate companies.

<Check>
  #### Requirements

  Lead requires Beneficial Ownership information in line with the CIP program reviewed during Due Diligence. At a minimum, this should include **all Beneficial Owners (UBOs) who are natural persons** with **direct or indirect** ownership of 25% or greater.

  * **Control Person:** you must also identify *one* natural person with significant responsibility to control, manage, or direct the business (e.g., CEO, COO, President), required regardless of ownership percentage.
  * **Thresholds:** if your KYB process expressly states a lower percentage than 25%, all beneficial owners meeting your stated percentage must be provided.
</Check>

## The "Drill-Down" Rule

A beneficial owner *must* be a natural person. If a business entity (a parent or holding company) owns 25% or more of the customer, you **cannot** list that entity as the owner. Instead, apply the same ownership requirement to *that* entity's owners. Continue up the chain until you have identified all *natural persons* with a 25%-or-greater *indirect* stake in the original customer.

<AccordionGroup>
  <Accordion title="Simple Ownership (Bob's Pizza Company)" icon="pizza-slice">
    * **Customer:** Bob's Pizza Company
    * **Owners:** Alan (individual, 60%) · Bob (individual, 40%, also CEO)
    * **Other individual:** Charlie (an authorized signer on the account)
    * **Action:**
      1. Create individual profiles for Alan, Bob, and Charlie with authorized-signer data.
      2. Create the business profile for Bob's Pizza Company.
      3. Link **Alan** as a **beneficial owner** (owns >25%).
      4. Link **Bob** as a **beneficial owner** (owns >25%) AND as the **control person** (CEO).
      5. Charlie does not need to be linked as an owner or control person.
  </Accordion>

  <Accordion title="Complex Ownership (SaaS Co)" icon="sitemap">
    * **Customer:** SaaS Co · **Immediate owners:** Parent Corp (entity, 80%) · Jane Smith (individual, 20%)
    * Drill down into Parent Corp (an entity owning >25%). **Parent Corp's owners:** Holding LLC (entity, 50%) · Mark Lee (individual, 50%)
    * Drill down again into Holding LLC. **Holding LLC's owner:** Susan Kay (individual, 100%)
    * **Final UBO calculation for SaaS Co:**
      * Jane Smith: 20% direct → **not** a 25% UBO
      * Mark Lee: 50% of 80% = 40% indirect → **is** a 25% UBO
      * Susan Kay: 100% of 50% of 80% = 40% indirect → **is** a 25% UBO
    * **Conclusion:** provide profiles for **Mark Lee** and **Susan Kay** as beneficial owners (authorized-signer data requirements); do **not** report Parent Corp or Holding LLC as owners; *also* identify and provide the profile for SaaS Co's **control person** (e.g., its CEO), who may or may not be one of these individuals.
  </Accordion>
</AccordionGroup>