Verification of identity – Entities

This applies to corporations, trusts, estates, partnerships or other non-corporate entities including unincorporated not-for-profit entities.

For more information and examples, visit the Instruction page for completion of Identity verification and third party determination for entity owners .

• As part of record keeping requirements, you must:

  • keep an information record on the entity and each person that is authorized to give instructions on the account,
    • g. up to three signing officers of a corporation/not for profit entity/other non-corporate entity, and a trustee or executor (of a trust or estate)
  • verify the identity of the entity, and
  • verify the identity of each person authorized to give instructions on the account
    • g. up to three signing officers of a corporation/not for profit entity/other non-corporate entity, and a trustee or executor (of a trust or estate)

  An information record for an entity includes:

  • Recording the name, address, and the nature of their principal business.
  • For universal and permanent life insurance products only:
    • For Corporations only:
      • Completion of form 5091 Corporate Resolution (for an applicant/owner that is a corporation) is required. We are required to keep a copy of the part of the official corporate records that contain any provision relating to who has the power to bind the corporation and complete transactions.
    • For non-registered wealth and investment products only:
      • For all entity types (including corporation/not for profit entity/other non-corporate entity, and trusts or estates)
        • You must keep a copy of the part of the official corporate records that contain any provision relating to who has the power to bind the corporation and complete transactions.
        • You must keep a signature card for every person authorized to sign on behalf of the account.
        • To satisfy the above two bullet points, all authorized users of the account must sign the 4830 form and for a corporation, partnership or other entity, complete form 4207 Certificate of Incumbency and obtain copies of either:
          • the articles of incorporation; or
          • the bylaws that set out the persons authorized to sign on behalf of the entity for the account.
        • For a trust or an estate, provide a copy of the trust deed or other documents establishing the trust or a copy of the will for an estate.
          
          

  An information record for persons authorized to give instructions on the account (up to three signing officers of a corporation/not for profit entity/other non-corporate entity, and a trustee or executor (of a trust or estate) includes:

  • their name, address, date of birth and detailed occupation/pre-retirement occupation, or in the case of a sole , the nature of their principal business

  To verify the identity of an authorized individual of an entity (signing officers of a corporation/not for profit entity/other non-corporate entity, and a trustee or executor) you may use one of the following methods:

  • Government-issued photo identification method or
  • Dual-process method

  Refer to the section “How do I verify the Identity of an individual” above for the details of these two methods.

  To verify the identity of a corporation, you must confirm it’s existence, record and confirm director names and record their occupations.

  You may refer to*:

  • a certificate of incorporation;
  • a record that has to be filed annually under provincial securities legislation; or
  • the most recent version of any other record that confirms the corporation's existence and contains its name and address and the names of its directors, such as a certificate of active corporate status, the corporation's published annual report signed by an audit firm, or a letter or notice of assessment for the corporation from a municipal, provincial, territorial or federal government.

  The record you refer to must be authentic, valid and current.

  You may confirm a corporation's name and address and the names of its directors from a publicly accessible database.*

  *Important note: Sun Life will perform a corporate search to confirm the existence of the corporation and the names of the directors on your behalf. The name, address and registration number of the corporation and the names of the director information that you provide on the applicable 4831 form must agree to the corporate search which validates the accuracy. The corporation must have an active status to open a policy/account.

  If there is a discrepancy between the information you have collected and recorded on the 4831 form and the corporate search results, you must obtain official entity records from the Client to resolve for the discrepancy.

  To verify the identity of an entity other than a corporation (e.g. partnership, trust, estate, other non-corporate entity), you may refer to and obtain a copy of:

  • a partnership agreement;
  • articles of association;
  • trust deed or other trust document;
  • a will; or
  • the most recent version of any other record that confirms its existence and contains its name and address ( e.g. Canada Revenue database).

  Exemptions:

  When opening an account, you do not have to verify the identity of a person or entity if the account is for:

  • a public body,
  • a very large corporation or trust, or
  • a subsidiary of those types of entities, if the financial statements of the subsidiary are consolidated with those of the public body, or very large corporation or trust.

FINTRAC Definitions

FINTRAC defines Public Body as:

• a department or an agent of Her Majesty in right of Canada or an agent or mandatary of Her Majesty in right of a province,
• an incorporated city or town, village, metropolitan authority, township, district, county, rural municipality or other incorporated municipal body in Canada or an agent or mandatary in Canada of any of them, and
• an organization that operates a public hospital and that is designated by the Minister of National Revenue as a hospital authority under the Excise Tax Act, or an agent or mandatary of such an organization.

FINTRAC defines a very large corporation or trust as:

A corporation or trust that has minimum net assets of $75 million CAD on its last audited balance sheet. The corporation's shares or units have to be traded on a Canadian stock exchange or on a stock exchange designated under subsection 262(1) of the Income Tax Act. The corporation or trust also has to operate in a country that is a member of the Financial Action Task Force (FATF).

For permanent and universal life insurance policies:
As of Sept 4, 2018, a form E4207 Certificate of incumbency is no longer required to be submitted for perm and UL policies and the supporting documents are only required for certain scenarios to support existence of an entity and beneficial ownership:

Scenario 1 - Multiple shareholders/Owners of an entity

As a general rule, if an applicant is a corporation, a form 4831-E Identity verification and third party determination for entity owners a Corporate Resolution (5091)  and relevant supporting corporate documents is mandatory.
Note: On subsequent levels of ownership, we require supporting documents if that level also has multiple shareholders owning 25% or more. A form 4545-E International tax classification for an entity  may also be required.

Scenario 2 - Sole shareholder/Sole owner of a corporation

If the corporation has only one shareholder/owner and no other individuals are authorized to act on behalf of the corporation, only a form 4831-E Identity verification and third party determination for entity owners , signed by the sole shareholder is required. No supporting documents are required from the client. If there are other directors or signing officers listed, supporting documents are required

Scenario 3 - Sole proprietorship that has not been incorporated

We do not require entity documentation on a "sole proprietor"; treat them as an individual client. The AML/ATF portion of the application or the form 4830-E Identify verification, third party determination and politically exposed persons (PEP) for individual owners , not the form 4831-E should be completed. No supporting documents are required from the client.

Verifying the identity of a corporation is an important part of our due diligence under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).It needs to be completed within 30 days of receipt of an application.

Below are tips for gathering all the information required to verify the identity of a corporation.

Company name

Some words in a company name may appear abbreviated. Reference the appropriate forms to confirm the exact, official corporate name (e.g. Articles of Incorporation, Certificate of Incumbency). Be sure to note:

• Company / Co.; Companies / Cos.
• Corporation or Corp.
• Incorporated or Inc.
• Limited or Ltd.
• Registered or Reg.
• District or Dist.
• And or &
• Periods or no periods or spaces after initials in the company name. Examples:  A.B.C. Company or ABC Company or A B C Company
• Pluralization. Examples:  “Holding” or “Holdings”; “Service” or “Services

Place of incorporation

Correctly identify the province/territory (or state, if applicable). Search engines are province/territory-dependent and searching the incorrect province or territory will result in a failed search.

Corporate Registration Number

Every company is provided a “Business Number (BN)”, which is a common identifier between a province’s or territory’s corporate registry, the Worker’s Compensation Board (WCB) and the Canada Revenue Agency (CRA). This unique 15-digit BN is assigned by the CRA and includes nine digits to identify the employer, two letters to identify the government program, and four digits to identify a specific account.

For example:  Company X” wants to register with the CRA for a Business Number, one GST/HST account, a WCB account and one payroll account. The company will receive a:

• Business Number:  12345 6789
• GST/HST account:  12345 6789 RT 0001
• WCB account:  12345 6789 NW 0001
• Payroll account:  12345 6789 RP 0001

For search purposes, provinces/territories may also provide a corporation with a ‘reference number’ to be used in place of the unique 15-digit BN. Corporate Registration Numbers may differ by province/territory or if federally incorporated. Please refer to the province-specific information noted below:

Alberta
9 or 10 digits; Generally starts with the number “2”; may be referred to as the Corporate Access Number. e.g.:  2123456789

British Columbia
7 digits; Generally starts with letters “BC”, often followed by a zero “0”; may be referred to as the Incorporation Number. e.g.:  BC0123456

Manitoba
9 digits; Often followed by ‘MC0001’; may be referred to as Business Number. e.g.:  123456789MC0001

New Brunswick
6 digits; May be referred to as the Reference Number (assigned by the NB Corporate Registry Branch). e.g.:  123456. 

Note: A unique 15 digit NB Account Business Number is assigned in conjunction with the CRA, and will not be displayed in corporate search documentation. The 6-digit Reference Number should be captured for VOI/corporate search purposes.

Newfoundland and Labrador
5 digits; May be referred to as Company Number. e.g.:  12345

Northwest Territories
7 digits; May be referred to as Registry ID. e.g.:  1234567

Nova Scotia
7 – 9 digits; May be referred to as a Registry ID number

Nunavut
7 digits; May be referred to as Registry ID

Ontario
9 digits; zeros could precede number; may be referred to as Ontario Corporation Number (OCN). e.g.:  001234567

Prince Edward Island
3 – 5 digits; May be referred to as Registration Number. 
Note: Can also search on date of registration.

Quebec
10 digits; May be referred to as Quebec Enterprise Number (NEQ). The first two digits indicate the type of enterprise: '11' for legal persons, '22' for sole proprietorships, and '33' for partnerships, associations and other groups. e.g.:1141234567. 
Note: Nnumbered companies may not automatically have the same Corporate Registration Number

Saskatchewan
6 – 9 digits; May be referred to as an Entity Number.

Yukon
5 digits; May be referred to as Corporate Access Number

Charities
A “BN/Registration Number” is used.It generally contains 9 digits, followed by ‘RR00X’ where ‘X’ is a number. e.g.: 123456789RR001

Federal
7 digits; May be preceded by one or more zeros; and may be followed by a letter D, M or R at the end of the number e.g.: 1234567R. 

Note:  often the 7-digit Corporate Registration Number is followed by a BN # containing 9 digits, then ending in ‘RC00X’, where ‘X’ is a number. The BN # is a Canada Customs and Revenue Agency Business Number (assigned by CCRA). Example:  BN#123456789RC001
United States

Dependent upon the state. Be sure to include state of incorporation.

Address of company (Optional, but valuable)

Full address of company, including street name, city, province/territory (state, if applicable), and postal code (zip code, if applicable). If an address is available, it will assist in an internet search if the company name / corporation number cannot be found.