Is the reequirement that a customer have a social security number prior to opening a bank account a banking regulation/ bank law or bank procedure? I informed our board of directors that it is a requirement of BSA.

The BSA does require a tax ID #, but there is a provision that if an account is opened without it, you must perform due diligence to obtain it. IRS rules require us to obtain on all accounts opened. Backup withholding must begin within 30 days on deposit accounts opened without a TIN.

Of course, that will change in 36 days when CIP becomes final.