What's the Dilly-o with business verification (KYB): a buyer's guide for credit unions
In August 2026, FinCEN exempted US companies from reporting their beneficial owners to it.12 Meanwhile, anyone can create a limited liability company (LLC) online with only a name and an address.3 Arizona received 208 fake-LLC complaints in September 2025.4
The Dilly-o
Start by checking what your digital banking platform or account opening provider already includes for business verification, also called know your business (KYB). If it has nothing, buy a US-focused KYB tool that checks state registries, beneficial owners and the tax ID, and that plugs into the systems you already run. Whatever you buy, keep your written procedures current, because the tool supports your program but does not replace it.
How we'd size up a vendor
- Registry coverage - does the tool confirm a business with the Secretary of State in every state where your business members are registered? Ask for live registry checks rather than a stale copy of the data, since a fake LLC can be filed in minutes.
- Fit with your systems - does it connect to your core and digital banking platform, or will your staff retype every result? Ask for a reference credit union on the same core as yours.
What changed this year
In August 2026, FinCEN ended beneficial ownership information (BOI) reporting for US companies.12 You still must collect it when a business first opens an account, when facts call earlier information into question, and when your risk-based procedures require it.5 You also still need written beneficial ownership procedures.65 Nacha's 2026 rules treat payments induced by misrepresenting identity, authority or account ownership as fraud, and Nacha stays neutral on the methods you use to detect it.78
Will it work with your systems?
Alkami announced its acquisition of MANTL in 2025.9 Lumin Digital says its digital account opening covers ID scans, liveness checks, know your customer (KYC) and credit checks.10 We've confirmed that Signzy is listed on the Jack Henry Fintech Integration Network for credit unions on Symitar.C Ask your provider whether KYB is built in, which KYB vendor sits behind it, and whether results write back to the member record on your core.
What other credit unions did
America First Credit Union built its digital business account opening platform with a partner, Loquat, Inc.11 Before you sign, we'd call peers like these and ask which checks run on their own and which still land on a person's desk.
What your examiner will ask
Federally insured credit unions have had to follow the beneficial ownership rule since May 11, 2018.12 Your customer identification program needs written, risk-based procedures.13 The FFIEC exam manual adds that the procedures must say when not to open an account.14 They must also set the terms on which a customer may use an account while verification is pending.14 Have your procedures, your vendor due diligence file and the signed contract ready to show.
What it costs
Most KYB vendors don't publish credit union pricing, so expect to ask for a quote. Enigma charges nothing for a KYB search that finds no match, and Persona and Sumsub bill per successful verification.1516 Watch minimums: a $20,000 annual minimum at 1,000 checks a year adds $20 to each one.17 Vendors don't publish implementation times either, so ask for a dated plan on your core. NCUA notes that some credit unions accepted significant buyout or termination penalties, believing they could not negotiate them.18 It adds that early termination, escape and default terms are often negotiable.18 We'd negotiate those terms before you sign.
Food for thought
FinCEN no longer requires US companies to report their beneficial owners to it.12 So we'd ask each vendor whether it checks a business once at account opening or keeps monitoring it afterward.
Dilly Labs research, written from our catalog and cited sources · updated . Credit unions pay nothing. Vendors pay a referral fee only when a contract is signed through us. It never changes rankings or this guide. How we work
Sources
- FinCEN Ends Beneficial Ownership Reporting Requirements for U.S. Companieswww.mofo.com
The rule permanently exempts domestic reporting companies from beneficial ownership information (BOI) reporting under the Corporate Transparency Act (...
- FinCEN BOI Rule: What Credit Unions Need to Knowcompliance4creditunions.com
** On August 11, 2026, the Financial Crimes Enforcement Network (FinCEN) issued a final rule permanently removing the requirement for U.S. companies ...
- How fake businesses can become a real problem for youwww.wmtv15news.com
### Why it’s easy to create a fake LLC Currently, anyone can create an LLC online using only a name and address.
- How fake businesses can become a real problem for youwww.wmtv15news.com
According to data from the agency, the Corporations Division received 208 complaints about fake LLCs in September 2025.
- FinCEN Eases Beneficial Ownership Verification Requirements: What Financial Institutions Need to Knowwww.mintz.com
Financial institutions are still required to establish and maintain written procedures that are reasonably designed to identify and verify beneficial ...
- FinCEN Streamlines Customer Due Diligence Requirementswww.americascreditunions.org
Going forward, credit unions may choose to take advantage of this exception, but doing so is optional; if the credit union wants to continue verifying...
- ACH Fraud Rules Are Shifting: What Nacha 2026 Means for Banks and Credit Unions - ThreatMarkwww.threatmark.com
Nacha defines “false pretenses” as the inducement of payment by a person by misrepresenting (a) that person’s identity, (b) that person’s association ...
- Credit-Push Fraud Monitoring Resource Centerwww.nacha.org
The Rules are neutral regarding specific methods or technologies used to identify fraudulently initiated credit transactions.
- Alkami Strategy and Business Modelumbrex.com
2025 · MANTL (announced in 2025) · Expanded Alkami further into digital account opening and onboarding, reinforcing the broader digital-sales-and-...
- Digital Account Openinglumindigital.com
## Comprehensive & secure Protect your institution from potential fraud in account opening through ID scans, liveness checks, Know Your Customer (KYC)...
- America First Credit Union's Digital Business Account Opening Sees Strong Early Adoptionfinance.yahoo.com
Developed in partnership with Loquat, Inc., the platform simplifies how entrepreneurs and local organizations begin banking with America First.
- NATIONAL CREDIT UNION ADMINISTRATION 1775 Duke Street, Alexandria, VA 22314bsaaml.ffiec.gov
FICUs and other covered institutions must comply with the rule, effective May 11, 2018.
- FinCEN Permits Banks to Use Alternative Collection Method for Obtaining TIN Informationwww.fincen.gov
The CIP Rule requires written procedures that: (1) enable the bank to obtain TIN information prior to opening an account; (2) are based on the bank’s ...
- Beneficial Ownership — Overview FFIEC BSA/AML Examination Manual 1 05/05/2018www.ffiec.gov
These policies, procedures, and processes should describe: • Circumstances in which the bank should not open an account. • The terms under which a ...
- KYC Pricing Index 2026: How Much KYC Costsbeverified.org
Persona and Sumsub bill per successful verification, Enigma charges $0 for a KYB search that returns no match, and iDenfy sells approved-only billing ...
- KYC Pricing Index 2026: How Much KYC Costsbeverified.org
Persona and Sumsub bill per successful verification, Enigma charges $0 for a KYB search that returns no match, and iDenfy sells approved-only billing ...
- Identity Verification Pricing: What KYC Costs in 2026didit.me
At 1,000 verifications per year with a $20,000 minimum, the minimum alone adds $20 per check on top of the stated rate.
- Evaluating Third Party Relationshipsncua.gov
For example, some credit unions have entered into third party agreements with significant buyout or termination penalties, believing the penalties or ...