Guidance comments in the Notes section

A brief tutorial on how to interpret bronID's guidance comments in the Notes section

bronID may include guidance comments in the Notes section to make the interpretation of the KYB status easier. To open the Notes section, go to the Portal > KYC > Results > Organisation and click on the row with the name of the entity you want to analyse. Next, click on the Notes tab in the slider that comes on the right side of the screen.

KYB Notes Section in the bronID Portal


Common guidance comments

Status: Rejected 
Comment Interpretation
Incorrect entity type The entity was submitted as a different entity type in comparison to how it is registered in the official business registers. The entity type must correspond to how the entity is enrolled in the official business registers. Although minor remediation is possible, most entities submitted as an incorrect type will be rejected. 
E.g. bronID would reject an Unregulated Trust submitted as a Private Company.  
The entity is an {{Correct Entity Type}} bronID will point out what is the correct entity type for the submitted entity. Note that an automated message is shown to the user to correct their action during submission; however, the user may ignore this message and still submit the entity incorrectly. In such cases, the KYB submission will be rejected. 
ABN does not exist The submitted ABN does not exist in the ABR register. 
ACN does not exist The submitted ACN does not exist in the ASIC register. 
The entity number does not exist in the {{Country/State}} register The submitted entity number does not exist in the {{Country/State}} register.
ABN/ACN does not correspond with the entity name The submitted ABN or ACN is of a different entity than what was submitted in the KYB submission. E.g. the user has submitted Citizen Pty Limited with ABN: 11 111 111 111; however, 11 111 111 111 is the ABN of an entity under the name The Citizen Family Trust. 
The submitted entity number does not correspond with the entity name The submitted entity number is of a different entity than what was submitted in the KYB submission. 

Status: Info
Comment Interpretation
The uploaded Trust Deed lacks pages that are material to this verification The uploaded Trust Deed lacks pages that are needed for the identity verification process. This is usually the case when the attached Trust Deed does not have the pages that include the Trust Name, the name of the Trustee(s) or the names of the Beneficiaries. This message is always paired with an Info request for a document (e.g. Complete Trust Deed).
The Trustee in the Trust Deed is {{Name of the Trustee}} bronID will provide the name of the Trustee identified in the uploaded Trust Deed or documents. This indicates that a different Trustee was submitted in the KYB submission. This message is always paired with an Info request for a document (e.g. Deed of Variation for the Change of Trustee). 

Status: Pending, Info, Verified, Rejected
Comment Interpretation
The regulation details of this SMSF have been removed from display in Super Fund Lookup due to their failure to lodge returns. The details of the submitted SMSF are removed from the Super Fund Lookup because the SMSF did not lodge the annual returns on time. This is a risk indicator and will affect the IDV risk of the KYB submission. 
Circular ownership detected. The entity directly or indirectly owns 25% or more of its shares. E.g. Company A is 100% owned by Company B, and company B is 100% owned by Company A. Often, circular ownerships involve non-beneficially held shares. As circular structures can be used to obfuscate true beneficial ownership, bronID will flag the entity and increase the IDV risk. This message may be paired with an Info request for a document (e.g. Trust Deed for the Trust holding the non-beneficially held shares by Company A in Company B). 
The Ultimate Holding Company is located in an off-shore or high-risk jurisdiction bronID will note if a holding company in the ownership structure is situated in an off-shore or high-risk jurisdiction. This is a high risk indicator and will affect the IDV risk of the KYB submission. 

bronID may include other comments relevant to the KYB submission in the Notes section.

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