We have a municipality that had an account with our bank, but closed it prior to October of 2003. Now, they are opening an account. One of the authorized signers, who was not a signer back in 2003, refuses to give us their SSN. What can we do and how should we proceed?? It is a touchy situation, as the account relationship is critical.

The four requirements are name, date of birth, social security number/TIN, and physical address. I mean these are REQUIRED not waved. I don't know how large account relationship it would be, but would you really want to take that risk??? especially BSA/AML/CIP are all hot spots for the regulators, examiners, and auditors.....

The CIP regulations exclude government entities from the definition of "customer;" the municipality isn't subject to CIP unless your program says it is. In addition, the CIP regulations don't require you to get anything from a mere signatory on any customer's account.

Look at the program adopted by your Board of Directors. If it requires you to get this signatory's SSN, this noose was tied in your bank.