quote]A tax ID # is not part of the CIP requirements unless it is part of your bank's policy......The law doesn't say we have to do this for all accounts, only interest bearing account, but we elected to do for all accounts. [/quote]
103.121(b)(2)(i)(4)
Identification number, which shall be:
(i) For a U.S. person, a taxpayer identification number; or
(ii) For a non-U.S. person, one or more of the following: a taxpayer identification number; passport number and country of issuance; alien identification card number; or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.
Can you explain why you think that a tax ID is not part of the CIP requirements??? If they have one - you have to get it, unless they are a non-US person.
_________________________
The opinions expressed here should not be construed to be those of my employer:
PPDocs.com