In regards to the USA PATRIOT Act CIP provisions: For addresses similar to a P.O. box, such as AIM Mail Services, Mailboxes Etc. (now The UPS Store), Pak Mail, Parcel Plus, PostalAnnex, PostNet and others that essentially compete with local post office services (by providing private mailboxes), do banks have any requirement to try to identify these types of addresses? Would we need to request an actual residential address? (In reading the rule and its preamble, these would be considered as business addresses and may constitute compliance. However, these could also be a means for bad people to open an account without providing a true physical address. These companies extend their business street address to customers and assign a box or suite number. The result is an address that cannot be distinguished unless it is listed on a fraud file somewhere.)
We are a commercial bank with a large number of business accounts. Many of these accounts have numerous signers who are bookkeepers and the like with no authority or control. Are we required to collect the ID of these individual as well as those with authority and control? Or are we permitted to collect the only ID of those who are in authority/control of the company as demostrated on a corporate resolution or similar documentation?
In opening corp, LLC, and partnership accounts, we do Telecheck and CheqSystems on the principals. We have them sign an authorization. We are now considering not doing that process. We would still require the appropriate documentation and could verify with the Secretary of State. I would like to know what your opinion is regarding verifying through CheqSystems and Telecheck or similar systems of the principals for these business accounts.
Does a corporate fiduciary (trust Dept) need any form of ID under CIP for testamentary trusts that they are opening as trustee. example: Jane Smith dies leaving a will and names the bank as trustee of the trust for the benefit of her grandchildren.
What are the NOW account requirements in regard to farm accounts eligibility? I have a situation with a father/son/son is this eligible?
FinCEN and the financial regulatory agencies have finally proposed a rule under the USA PATRIOT Act to implement customer identification procedures. This isn't a surprise.
HUD appears to be making a big play for consumer attention. The timing - several months before a Congressional election - is probably no accident.
This is a strange situation. We have a business account that we can not find resolutions for. From looking at the signature cards, it would appear that person A opened the account and added person B four months later. At some point in this business relationship, it went sour between person A and Person B. Person B came in and requested we remove person A from the account. We told person B that we had no authorization to remove person A based on person B's request alone. (got this?) We told both of them that they needed to resolve the situation and one possiblilty was to close the account reopen another with the sole person on it. What happened, however, was Person A withdrew funds while Person B wrote checks causing the account to go into overdraft. NOW person A wants to be removed. We say no, not until the account is brought back to zero. Please explain what procedures and/or regulations pertain to removal of names from a business account!
Financial education is more important than ever. The FDIC was the first regulatory agency out of the chute with its "Money Smart" program.
Can you give me any information on authorized signers on a business account?