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Latest Compliance - Interest Reporting Topics

Joint Account w/Right of Survivorship Liability

10/15/2012

A joint account with right of survivorship that has a deceased primary owner: What are the ramifications of reporting interest earned on a deceased primary owner's SSN when an account has a surviving joint owner? Who is liable for these ramifications - we, the institution, or the surviving owner(s)? When a primary owner dies, we request that the surviving owner(s) close the existing account and re-open a new one in their name, but we don't REQUIRE it. Are we doing something wrong?

Foreign Accounts - Interest Reporting

02/25/2008

Does the bank need to report the interest earned on an account of a foreign individual with a SSN not valid for employment? Does it need to report the interest earned on an account of a foreign individual with a SSN valid for work only with DHS authorization? Does it need to report interest earned on an account of a foreign individual with ITIN?

Joint Accounts, ITINs, and Interest Reporting

10/20/2003

We have a joint account for two individuals; one is a nonresident alien with an ITIN, the other one is a US citizen with a SSN who is an 'in case of emergency' signer. Is the interest reported on a 1042S using ITIN of primary owner or does the interest HAVE to be reported on a 1099 using the SSN of the emergencyonly signer?

Resident Aliens, NonInterest Accounts, and W8BENs

03/03/2003

When a new customer is not a resident or is a resident alien opens an account, we normally require them to complete a W8BEN to claim foreign status and prevent us from reporting interest earned on the account. If they open an account that does not pay interest, are they still required to complete a W8BEN?

Requiring A W8BEN For Non Interest Bearing Accounts

02/24/2003

When a new customer is not a resident or is a resident alien opens an account, we normally require them to complete a W8BEN to claim foreign status and prevent us from reporting interest earned on the account. If they open an account that does not pay interest, are they still required to complete a W8BEN?

Most Popular Compliance Content

TILA Disclosures Given to Business Entity (Reg Z)

02/16/2020

If TILA disclosures are provided in a loan to a business entity and the APR is understated - is this a violation of regulation Z although loans to business entities are exempt from the coverage of Regulation Z?

Threshold for Regulation Z Coverage (Non-RE Loans)

02/16/2020

Should non-RE loans that exceed the dollar threshold for Regulation Z coverage still be considered consumer loans as far as coding and reporting? We have a difference of opinion. One side believes the Reg Z exemption essentially changes the loan into a commercial loan in every way. The other thinks that the disclosures in the documentation is where the exemption is primarily seen and the loan should be coded and reported exactly like any other loan of its type that is under the threshold. Any clarification would be appreciated.

CRA Changes for Intermediate Small Banks

02/16/2020

Our bank is an Intermediate Small Bank under the current CRA rule, with an asset size of $750 million. Will we still be treated differently from large banks under the proposed rule?

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