We have a branch near a bowling alley. The employee of the bowling alley typically comes into the bank to open accounts for the various bowling leagues. The bowling alley employee is not a signer on any of the accounts that we open. By definition, this is the person that opens the account, but they are not the customer. Do we identify this individual or must we have a signer from each account come in to be identified?

Been there. What do you use for a TIN?

It would seem you must ID the signers of these accounts. The alley employee is not your customer.

From the final rule, "customer" is defined as "...and any individual who...opens an account for an entity that is not a legal person, such as a civic club."

I may be wrong, but it seems to me that the bowling alley employee is the customer, according to this definition. Definitely not logical, but we're dealing with regulations.

If I am right, this might be a good time to have a talk with the bowling center management about changing this practice. Most fall/winter leagues will have started by 10/1, so hopefully it wouldn't be a major change at a critical time.

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Been there. What do you use for a TIN?

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My understanding is that the team/league has to apply for an EIN.