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Latest Compliance - Corporate Accounts/Checks Topics

Beneficial Owner Certification

08/09/2020

Regarding a Beneficial Owner Certification: ABC, LLC (Borrower) is 100% owned by DEF, Inc. DEF, Inc. is 33.33% owned by 3 individuals. Would I need to list the individuals as having 25% or more ownership on the certification, even though they are not owners of ABC, LLC?

Opening Professional Limited Liability Company

08/25/2019

We have a customer wanting to open an Professional Limited Liability Company. What should the bank get for documentation? Do we need the Admission to Transact Business and Articles of Organization?

Open DBA Under LLC- Certificate of Assumed Name

06/23/2019

We have a LLC wanting to open a DBA under the LLC. The TIN number and the Article of Organization only has the LLC's name. 1. Does the LLC need to get an Certificate of Assumed Name filed with the Secretary of State? 2. Will they have to file the DBA at the county also? (We know at this time the DBA is filed under someone else's name at the county currently.)

Opening Business Account-Tax ID & Name Change

02/17/2019

We have a customer trying to open a business account. He has provided us with a 2017 Tax Return, which gives us the Tax ID under which the business is operating. I typed this Tax ID number into the Texas Comptroller of Public Accounts website and got a hit, showing that the business is in good standing. However, the name that was listed has been changed since the Comptroller website was updated (surprising since the 2017 Tax Return reflects this change). The company is not currently operating and, therefore, the individual opening the account does not have access to documentation of the name change for the Secretary of State office. The question is, do we have what we need to open the account? The tax return and Comptroller website verify that the Tax ID number is valid and in Good Standing, but they disagree on the business name.

Deceased Corporate CD Signer-Adding Signers

02/04/2018

A corporate CD signer passed away. The daughter and son would like to be added to said CD. On the State of Florida's Division of Corporations web site, both son and daughter are registered for the corporation. The daughter shows as a registered agent, and the son as officer/director plus there is a third person who is also as officer/director. Can we add the daughter and son as signers on CD? Do we have to add the third person as well, or does a court document and/or trust need to be presented showing son/daughter/3rd person as either owners/trustees before adding the names?

What Happens When Customer Passes-LLC Using EIN #

10/22/2017

We have a single-member LLC using an EIN number. The member is asking what happens to the account when he passes away, will it go to his estate or does it need to be in his business papers to show where is goes? The account is held in Iowa and they run the business out of Minnesota.

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COMPLIANCE Q&A: Multiple control people for the same EIN?

Question: Is it possible to have different control people for different accounts with the same Employer Identification Number (EIN) or should you have the same control person for a

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Reg E Question About Credit Card Fraud

10/25/2020

When a cardholder has a fraud alert on their card and they tell the fraud center that the transactions are NOT fraud, the fraud center reopens the card. Now the customer has roughly 10 or more charges from the same company that she just said were not fraud. Now she is claiming that they are all fraud. (including the original charges) What do we do?

Chamber of Commerce Cash & Prize Giveaway

10/25/2020

Our Chamber of Commerce is hosting a cash & prize giveaway to encourage people to shop local during the holidays. As a member of the Chamber of Commerce, the bank has been asked to pass out tickets as entries to win. Each business has a limited number of tickets. Employees of the bank are not allowed to obtain any tickets from the bank, but can from other businesses participating. My question is, can we offer multiple tickets as incentives for our customers to use other services we offer? Examples would be: 1) A customer comes in to make a deposit= 1 ticket. If they sign up for online banking while here we will offer an additional ticket. 2) A non customer comes in to cash a check= 1 ticket. If they open an account with us we will offer additional tickets. 3) A customer asks about a home loan= 1 ticket. If they qualify, they can earn additional tickets. If they decide to finance with us more tickets.

How to Complete a CTR for Local Diocese

10/18/2020

A question came up during a recent audit in regards to how a CTR would be completed for a local Diocese. This particular Diocese has a few different churches using the same EIN. Our system recognizes large currency transactions that we compare to see if a CTR was completed. My question is, would a CTR be filed on that specific church when deposits of cash are over $10k, or on the Diocese?

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