09/06/2004
Can a business customer be exempted on the same Designation of Exempt Person form for more than one tax ID number, or does each TIN need its own exemption and own form?
03/22/2004
09/08/2003
We have an Amish population in more than one of our banking areas. Recently we are having problems with Amish people depositing cash or purchasing money orders with cash and they claim not to have identification or a Social Security number, stating their sect prohibits these items. I think I remember something in the past about particular procedures for Amish, but I can't find anything. Is there any reason to treat them differently from any other person? If so, where do I find the information?
07/14/2003
Student loans are applied for at the college and sent to the state regents for approval. They are then sent to us to fund. We never see the applicant. The name, address, TIN and birth date are fields on the application. Any comments on the verification process? Banks are not permitted to perform credit checks. We do perform OFAC checks.
07/07/2003
Regarding the TIN requirement of BSA 31 CFR 130.34, does it apply to the members of religious groups who do not have SSNs or TINs due to their beliefs? If they want to open an account, are they required to furnish a TIN? What if they don't have a TIN and they are an existing customer?
07/07/2003
Does a W8 BEN have an expiration date? How often do we need to recertify?
06/16/2003
We have a customer who is in the car wash business and been with the bank 18 months. He routinely makes cash deposits over $10,000. We would like to exempt him. However, as he opens new locations, he puts each one under a new TIN. For the new locations (new TIN and new account number), do we have to wait 12 months on each before we could exempt the accounts?
06/02/2003
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.
06/02/2003
When opening an account for a new customer must the individual present his or her social security card or provide documentation to verify the SS#, as a result of the provisions of the USA PATRIOT Act? Is not providing the SS# along with proper ID enough? Many individuals don't have anything with the SS# on it or carry it with them. We don't want to turn prospective account holders away for not having their SS Card.
04/21/2003
When opening a DDA in an individual's name, DBA as a company, can we use the individual's social security number, or are we required to use a business tax ID number?