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KYB Procedures
Sameer Kapur avatar
Written by Sameer Kapur
Updated over 7 months ago

This document provides the possible warning and failure signals that may be found when reviewing the KYB report. Recommended recourse is provided along with each signal.

  • Example of where warning and failure signals are provided on a KYB report

Business Name - Verification

Warning - Similar Match

  • Meaning: Similar match identified to the submitted Business Name

  • Recourse: Verify the business name by reviewing additional business documents (e.g., business registration, licenses) submitted by the applicant. Confirm the accuracy of the submission and check for typographical errors or legal name versus DBA (Doing Business As) discrepancies.

Failure - Alternate Name

  • We believe the submitted TIN is associated with “[the name that we have found]” (Commonly is the name of an officer when an SSN is submitted vs. the EIN)

  • Recourse: Contact the applicant to clarify the discrepancy between the TIN and the business name provided. Request documentation that proves the business name's association with the TIN, such as IRS confirmation letters or updated business registration documents.

Failure - Unverified

  • Unable to identify a match to the submitted Business Name

  • Recourse: Inform the applicant of the failure to verify the business name and request additional or alternative documentation that can verify the business's existence and legal name. This may include articles of incorporation, tax returns, or a certificate of good standing from the state.

Office Address - Verification

Warning - Approximate Match

  • Identified an address within 0.2 miles of the submitted Office Address (Commonly means that the address is partially verified at line 1 or line 2)

  • Recourse: Confirm with the applicant if there has been a recent move or if there's an alternate address (such as a mailing address different from the physical address) that could explain the discrepancy. Use any mapping tools to verify the proximity and correctness of the address provided. Ensure that address line 2 is added when needed.

Warning - Similar Match

  • Identified a similar address

  • Recourse: Request clarification and additional documentation from the applicant to confirm the correct address. This may include utility bills, lease agreements, or property tax receipts in the business's name.

Warning - Incomplete Match

  • Identified a partial match with a submitted address that is incomplete

  • Recourse: Contact the applicant for a complete address, including any missing components such as suite numbers, building names, or correct postal codes. Verify the updated address against documentation provided.

Failure - Unverified

  • Unable to identify a match to the submitted Office Address

  • Recourse: Notify the applicant of the failure to verify the office address and request comprehensive proof of address that associates the business with the name/TIN. Acceptable documents may include a recent commercial lease agreement, mortgage statements for the property, or confirmation of address service from a recognized postal authority.

TIN Match

Failure - Not Found

  • The IRS does not have a record for the submitted TIN and Business Name combination

    • Two cases when this happens 1) either the combo is wrong or 2) TIN is not available via the IRS yet (generally businesses formed < 30 days. In these cases, we can maintain re-tries to verify once the TIN is available)

  • Recourse: Request that the applicant verifies the TIN and business name submitted. Ask for a copy of the IRS-issued document where the TIN was assigned, such as a CP 575 notice or 147C letter, to ensure that the submitted information matches IRS records.

Failure - Error

  • Invalid TIN or IRS is Unavailable

  • Recourse: Instruct the applicant to double-check the TIN provided for any typing errors. Review to see if it matches against submitted EIN documents. “Rerun KYB” to check again.

Failure - Mismatch

  • We believe the submitted TIN is associated with a different Business Name

    • Commonly is the name of an officer when an SSN is submitted vs. the EIN

  • Recourse: Notify the applicant of the mismatch and request documentation that can verify the association between the TIN and the business name. This might include tax returns, IRS notices linking the TIN with the business name, or a letter of explanation if the name change has not yet been updated with the IRS.

People - Verification

Warning - Partial Match

  • Similar match identified to the submitted People

  • Recourse: Check Plaid IDV to ensure that authentic identities were used. Ask and review documentation that links these individuals to the business, such as ownership papers, board of director listings, or signed statements of significant control over the company's operations.

Failure - Unverified

  • Unable to identify a match to the submitted People

  • Recourse: Ask and review documentation that links these individuals to the business, such as ownership papers, board of director listings, or signed statements of significant control over the company's operations. Review Plaid IDV to ensure that the applicants are authentic.

Watchlists

Failure - Hits

  • X Watchlists hit(s) have been identified

  • Recourse: Check to see if it is a relevant match. If it is, escalate the case to the credit union's compliance or legal department for a detailed review. This review should involve analyzing the nature of the watchlist hit(s) to determine the relevance and accuracy concerning the applicant. It may require obtaining additional information or documentation from the applicant to clarify or refute the match.

SOS Filings - Domestic

Failure - Domestic Missing

  • The business has no domestic filing

  • Recourse: Contact the applicant to provide evidence of a domestic filing, such as a certificate of incorporation or registration, especially if the business claims to operate domestically.

Failure - Domestic Inactive

  • Inactive domestic filing found

  • Recourse: Request clarification and supporting documentation from the applicant regarding the inactive status. If the business is still operational, ask for recent proof of reactivation or compliance with state requirements.

Warning - Domestic Unknown

  • No domestic filing status provided

  • Recourse: Advise the applicant to provide the current status of their domestic filing. If unavailable, suggest applicant contact the state's SOS office to obtain official status documentation.

SOS Filings - Match

Failure - Submitted Not Registered

  • The business is not registered in the state of the submitted Office Address

  • Recourse: Inform the applicant of the discrepancy and request documentation of state registration in the office address's state or an explanation if the business operates in a different state than the office address.

Failure - Submitted Inactive

  • The business is Inactive in the state of the submitted Office Address

  • Recourse: Ask the applicant for an explanation or recent evidence of reactivation with the state. This may include updated state filings or correspondence with the state's SOS office.

Warning - Submitted Unknown

  • The submitted state does not make filing status available

  • Recourse: Since the state does not make filing status available, request any available documentation from the applicant that can confirm the current operational status of the business with the state.

SOS Filings - Status

Warning - Partially Inactive

  • X of Y filings found are Inactive

  • Recourse: Request detailed information and documentation on each filing to determine the reasons for inactive statuses and any efforts to reactivate.

Warning - Partially Unknown

  • X of Y filings have no status provided

  • Recourse: Encourage the applicant to obtain and provide current status reports from the SOS office for each filing where the status is unknown.

Failure - Inactive

  • The business has no Active Secretary of State filings

  • Recourse: Notify the applicant of the need for proof of active SOS filings to proceed with the application, suggesting steps to reactivate their status if necessary.

Failure - Not Registered or Inactive

  • The business has no Secretary of State filings // The business has no Active Secretary of State filings

  • Recourse: Advise the applicant that evidence of active registration or steps being taken to register/reactivate with the SOS is required for further processing of their application.

Office Address - Property Type

Warning - Residential

  • Submitted Office Address is a Residential property

  • Recourse: Contact the applicant to confirm if the residential address is indeed used for business operations. If so, request documentation to support this, such as a home office permit or business license that lists the residential address. This is to ensure compliance with zoning laws and to verify that the business operation from a residential property is legitimate.

Office Address - Registered Agent

Warning - Registered Agent

  • Submitted Office Address is actually the address of a Registered Agent, not the actual business

  • Recourse: Inform the applicant of the finding and ask for the actual physical location of the business operations. If the business does not have a separate physical office space, request an explanation and any available documentation that supports the nature of the business operations conducted through the registered agent's address. This step is important to differentiate the administrative address from the operational address of the business.

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