We think we heard Brian Crow say, at TopGun Mar. 2020), that if we acquire a loan from a non-covered institution, that did not collect Beneficial Ownership certification from a legal entity borrower, we now must do so. I'm looking for citation of that requirement in Regs or guidance etc. We're about to do exactly that scenario.
I have a compliance question related to our CIP documentation process. An IRS SS-4 Form is typically a required document to verify the Employee Identification Number. We are asking if a company’s Tax Returns and Department of Revenue Letter can be used as substitute items in lieu of the SS-4?
XYZ, LLC was opened with a certification of two individual signers owning 10% and 16% of the company. However XYZ’s company agreement stated that another LLC (ABC, LLC) owned 90% and one individual (one of the signers) owned 10% interest of the company. The ABC, LLC was not indicated on the certification.
Based on the XYZ’s company agreement, do we need to request beneficiary ownership information on the ABC owners?
Would failure to collect beneficial ownership information at account opening (CDD) or a reason for not needing CDD certification of beneficial ownership be considered a CIP exception?
When addressing Beneficial Ownership-Statutory Trusts, what is the best way to discern a trust that is a "statutory trust created by a filing with a
Secretary of State or similar office"? We have questions regarding how to tell the difference between a regular family trust and a business trust.
Do you need to complete a new CIP form for a change of address?
What is the proper identification for cashing checks or making deposits?
If a client has a Social Security card stamped for work only, can that be used for opening accounts in a bank?
When opening accounts for the City (Police, Fire Department, etc.) what documents are we required to collect? Here is why I ask:
“Earlier this week the city of XYZ opened a new savings account. They have been a customer since 1977, therefore we don’t have all the paperwork that is now required. This account was brought in by the Chief of Police and the Warrant Officer saying that it needed to be a new account under the “CIF” of the City of XYZ, but needed to be worded titled “The State of TX vs ….. defendant.” There has been an account like this in the past, the defendant is in jail and it's confiscated funds. My question is, what all documents do we need?”
I have a new customer who has a single member entity that is disregarded for tax purposes (rental income and expenses are reported on personal tax return), but has been assigned an EIN separate from his SSN. The entity is 12 years old and he has misplaced his letter from the IRS verifying the LLC's EIN. What is the easiest way to document this to comply with CIP procedures? Can I take his and his accountant's word that the EIN is correct?