Combining the TIN certification
by John Burnett Guru BIOS
Question: Our confirmation form on deposit accounts has two parts: The first part requires the customer to sign to agree that they have received the
bank’s terms and conditions for the account they just opened. The second section is the TIN certification, where they have to sign to certify their tax I.D. number.
My marketing folks have seen banks that combine both of these sections into one. Is this permissible, and if so, can you direct me to a section in the IRS code or
Reg DD that specifically allows this?
Answer: If you use “substitute W-9” language in your deposit documents (which is what you are doing), the
IRS requires that the signature in the W-9 section be separate from any signature required as a condition of opening the account. You cannot combine the two sections of the form.
The original version appeared in the September/October 2004 edition of the Oklahoma Bankers Association Compliance Informer.
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