Guide to Dwolla Controller and Beneficial Ownership Rules

Due to customer due diligence rule requirements under the Bank Secrecy Act, our funding partner Dwolla requires us to collect controller information and beneficial owner information for the business entity.

A controller is a person who holds significant responsibilities to control, manage or direct a company or other corporate entity (e.g. CEO, CFO, General Partner, President, etc).

A beneficial owner is a person who — directly or indirectly — owns 25 percent or more of a company. If there are no natural persons who own 25 percent or more of a company, then no information needs to be collected.

A beneficial owner cannot be another company (or other corporate entity), nor a nominee owner.

Please contact with any questions about the collection of this information.