These are two separate issues. Think about the case of the UTMA account. Your customer is the custodian, and you get the custodian's SSN for the purposes of CIP. But the beneficial owner of the account (and the party responsible for taxes on the income) is the minor, so you also obtain the minor's SSN for 1099-INT purposes.
Your case is no different. You get ID on your customer under the CIP rules. But you also obtain and use the TIN of the beneficial owner of the account for tax reporting purposes.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8