We have an account for a society at our local university. The account is titled with the name of the university and the initials for the society. The society does not have a tax id #, so every year when they elect new officers, the tax id# of the new chairman is used for the account and the new chairman is listed as the primary owner. The information for the previous chairman is removed. During my CIP review, I noticed that only a post office box address was on our system for this account so I requested a physical address for the new chairman/account owner. Am I correct in assuming that CIP requirements apply to the person whose name and tax id# are used for the account?

If the organization is a legal entity, it can be your customer for CIP, and it would need its own TIN. If it isn't an entity, the individuals opening or controlling (after changes) are your customers for CIP purposes, regardless of which address or TIN you have for the organization.

The organization does not intend to apply for a TIN. The new chairman signed a revised signature card for the account. He is the only signer on the account. Thanks for your input. The CSR responsible for the account did not want to add the physical address for the account owner because it "isn't really his account".

Why not apply for an EIN? It's simple!

At our bank, TINs and names must match. We would not permit the customer to use his SSN if the organization has its own name. Booster clubs, bowling clubs, knitting clubs, you name it -- they are required to apply for an EIN to open an account at our bank.

You need a correct TIN in the event you need to file a CTR.

You have to address these types of accounts in your CIP policy.
We allow a few groups to have accounts without a EIN; what they have to do is put the account in the primary signers' name, and they can then put the group name in the second line.
Since these accounts are non-interest bearing, the customers are okay with it.
But they are accounts/groups that have minimal activity and minimal cash such as card clubs for seniors that just take small dues from their members to pay for lunch etc.
If it is a group that does any type of fundraising, they would have register with the state and have an EIN.

I think in your case, if the account is in the name of the local university I would use the uni's EIN number.
And perhaps just the fact that they have officers and elections makes them a more formal group that should be registered.

OK. I am in the mood to muddy the waters here.

Let's suppose you are asked to open a demand deposit account for "King Pin Aces," a bowling team. It's just a group of individuals who want to pool some funds to pay for team bowling shirts, the end of tournament awards banquet, lane fees, and miscellaneous other stuff. Who's your customer?

• Do the Aces have a legal existence? No.
• Can you require them to apply for an EIN and use it in connection with the account? Yes.
• Does that give them a legal identity as an entity? No.
• Who is your customer? The individuals opening the account.
• Whose TIN or TINs must you obtain? If the Aces have their own EIN, you can take that number and assign it to the account. But you must also complete CIP requirements for each of the individuals opening the account.

The existence of officers and elections does not an entity create.

To add to the mix, suppose the individual opening the account (in either instance - the "society" or the bowling league) has garnishments or owes back taxes/child support. Because his/her SSN is on the account, the funds in that account could be depleted. Because of that, our institution insists on the Name/TIN match as well. Applications "for banking purposes only" (as indicated on the SS4) are swift and painless.

Well unless the CSR has the authority to rewrite the USA Patriot Act ... he/she doesn't really have a choice.

Just because the CIP regulations require that you obtain a residential or business street address for each customer opening an account does not mean that you must use that address for mailing purposes. The two are not connected.