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Latest Compliance - Limited Liability Company (LLC) Topics

LLC w/Series But Not Separate EIN

07/22/2018

Can an LLC with a Series that does not have a separate EIN be linked to the account as an assumed name (DBA)? We have an LLC customer that does have a Series without an EIN. The customer wants the Series attached to the checking account as an assumed name. I was told years ago that an LLC that has a Series would either have the Series with its own EIN and linked to the account as primary without the LLC name, or the Series would be added as a subtitle on the account and not linked as a DBA.

EIN for LLC If Single Member is a Trust?

06/17/2018

If a customer wants to open an account as a single member (or sole member) of an LLC, but the single member listed on the Formation of LLC paperwork is the customer's single person revocable trust, can the customer still use their SSN to open the LLC account or should they get an EIN for the LLC since the single member is a trust?

Can LLC Use 2 Names for Same Loan#?

01/28/2018

1.Does a customer have to have a TAX ID# if ​it is ​listed under su​n​biz​ (the Florida Secretary of State's website for businesses)​ as a​n​ LLC? 2. Can a​n​ LLC use two name for the same loan ​number, such as its LLC name and a DBA​?

Push-Back from Customers for LLC Requirements

10/22/2017

There is some ambiguity regarding LLCs at our institution. We require LLCs to have a TIN, and will allow a SSN for sole member LLCs. We also ask that LLCs register with the VT SOS and provide us with an operating agreement. The pushback we get from customers and sometimes their attorneys is problematic. Are we out of line in our requirements?

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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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