Is there a regulation or law that mandates a joint account that is tax reportable under a deceased holder be closed and a new account opened for the surviving joint owner OR is this just a policy that some institutions come up with to reduce some sort of liability? If it is a reduction in liability, what is the liability of transferring the reporting tax ID to another party after an account is opened?
We have a business customer that has a corporate account with a tax ID#. He is also a member/manager of an LLC that uses the same tax ID as the Inc. Both the Inc and the LLC have been filed with the state of WY. He is making deposits into the Inc. account but some of the checks are made payable to the LLC and some to the Inc. I thought that if you have an LLC and Inc. you would have to have a separate account for each entity. The customer tells us that he does not need a separate account as the LLC account conducts all business and operations through the corporate account. Is this a true statement?
Is there any regulation that requires obtaining/retaining a copy of a social security number and drivers license for any and all checks cashed for a non-customer, whether it is an on-us check or a check from a non-customer to an existing bank customer? We do understand the need to pull OFAC on all transactions that involve a non-customer no matter the amount of the check. It is very time consuming to make copies of IDs and the checks. Are examiners going to the extreme? If we check identification, it seems that with the OFAC that should suffice. Are all banks required to do this now?
What documents are required for opening a Community/Volunteer Group? It's not a Corp. or an LLC and it has a Tax ID.
I know a SAR is only completed when the account holder is doing a transaction with cash. Is there ever a situation where it should/could be filed without the use of cash? I have a member that has sent several wires overseas in the last few weeks.
We have a new teller that cashed a $11,500 check for a non-customer. She verified the customers ID and got all the required information for the CTR except for his SSN. We have called the individual and he refuses to give us the SSN. How do I proceed with the CTR and is a SAR necessary?
If the government sends tax refunds via cards instead of checks this year what type of card will be used? Can the bank impose a fee if the card is for a non customer? And will the taxpayer's name be on the card?
We currently have three IOLTAs. One was a brand new attorney's office while the other two attorneys had existing bank accounts that we subtitled IOLTA. They all have their tax ID number for reporting purposes. Do I need to change these?
What are the CIP requirements for new signatories on an existing business account? Am I required to obtain TIN and physical address on the signatories? The business account is well established with the bank, however the signers are brand new.
Do I need to collect the wife's CIP information if she is just a grantor on the Deed of Trust? She is not a borrower, she is just signing the Deed of Trust.