OK - This is still a gray area to me, how does the W8 form work and does it meet the requirement for CIP for a TIN? If so, how do I doument this appropriately?
Thanks!
Lynda

Lynda,
CIP requires that you obtain an identifying number for the customer. Usually this is the SS# or TIN but for those customers who are not US persons and who do not have a SS# you need some other number, such as passport number. I think it is also a good idea in these cases to have the customer sign a W8, even if the account does not pay interest, so that all customers either sign a W9 (or substitute) or W8.

The W8 would not meet the requirement by itself.
As DevsFans stated, we have it signed regardless of the type of account that is opened, but if it is a Non US Person, I think your CIP requirement is met with the passport being given and documented as the ID.
As always, ensure that your CIP program/policy reflects all these parameters or you will be cited for not following your own policy.
Hope this helps you.

OK - so, just to clarify, IF we obtain the Passport number and do a W8, and that's what my program states, I'm covered regarding the regulation. Is that correct?

THANKS!

CIP requires you get a name, number (passport will do), address and DOB.

If the account is interest bearing, the Internal Revenue Code requires you to get a W-9 or its equivalent from a U.S. Person or a W8-BEN or its equivalent from a non U.S. person.

The W8-BEN is not connected to CIP. It fulfills separate, unrelated requirements of the IRC.