07/07/2003
Generally, the definition of consumer is someone using an account for "personal, family or household purposes." However, Reg E simply defines a consumer as a "natural person" [205.2(e)]. When dealing with a sole proprietorship account (e.g., "Jane Doe d/b/a Jane's Flowers," or "Jane's Flowers, a Sole Proprietorship," does Reg E cover the account the account is for a business purpose, but considered to be owned by a natural person?
03/03/2003
In filing a CTR we have a situation in which a sole proprietorship, the owner, and an authorized signer are on the title of the account. Is it proper to treat each of these individuals as beneficiaries in Section A?
07/01/2002
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!
05/06/2002
Can you give me any information on authorized signers on a business account?
02/11/2002
Could you explain the difference between a MMDA and a NOW account to me?
11/05/2001
Can a sole proprietor use the same EIN for several business tradenames or must he have a separate EIN for each business tradename?
05/07/2001
Can sole proprietors be treated like corporations as it relates to privacy notices?
05/07/2001
We are trying to establish a 5 point customer verification process. What are other financial institutions using? I've been told that it is not recommended to simply use social security and driver's license numbers as they are too easy to obtain on the internet.
10/01/1997
We keep hearing that there will be Know Your Customer regulations "soon." We have been hearing this so long that the question seems to be will it really happen and, if so, when.