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#121937 - 10/10/03 05:07 PM New TIN Rule
Patsy Cline Offline
Diamond Poster
Patsy Cline
Joined: Sep 2002
Posts: 1,117
On the road...
I understand that effective 10-1-03 banks must obtain a taxpayer ID number from a customer prior to opening an account.

BUT.. does that mean the provision to maintain a list of the names, addresses, and account numbers of TIN deficient accounts no longer exists? Obviously we won't have any new accounts without TINs... but what if we have some existing accounts without TINs?

Also... does anyone know were I can find this requirement in BSA if it still applies for existing accounts?
Michelle CRCM

"What would you attempt to do if you knew you could not fail?" ~ unknown

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#121938 - 10/10/03 05:20 PM Re: New TIN Rule
SJB Offline
Diamond Poster
Joined: Jun 2002
Posts: 1,210
The new requirements do not replace or "undo" any pre-existing requirements. Accounts without TINs are treated as they were before except now you cannot add an owner to the account without going through the CIP steps and you cannot open a new account for that non-TIN'd (new word) customer.
BSA is still BSA, CIP only adds to it.
My opinions are not legal advice and are worth what you paid for them.

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#121939 - 10/10/03 05:48 PM Re: New TIN Rule
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,793
Cape Cod
The requirement of a list of accounts without TINs applies to accounts opened prior to 10/1/2003. The regulation requires that you obtain a TIN (or other identifying number for non U.S. citizens) for all accounts opened after 9/30/2003. So the reg doesn't anticipate a need for these accounts to be included on a missing TIN list.

There is a provision in the new regs that permits you to open a "pending TIN" account, but only if you are sure a TIN has been applied for. And you are required to have a procedure for force-closing such accounts if a TIN is not received within a reasonable amount of time. As someone has suggested, following up on "pending TIN" accounts may be more trouble than it's worth, so some banks are using a "no TIN, no account" approach.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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