I am new to Operations/Compliance and I am the only one here today, so I need your help. A customer John Doe has 4 DBA's using his SSN and he wants to open one account and list all 4 DBA's. I say no, one account per DBA. Am I correct? Thanks

How many TIN's are there?

One TIN, the customer is using his SSN.

I have had this situation before where we allowed one account with multiple dbas as long as the customer can prove (via business licenses) that he is indeed the owner of all the dbas. I would think that this would be an accounting nightmare, however, for him!

I'm not sure I like it, but if they are all the same TIN, they are all him. Therefore, it is OK.

I'd warn the client of your potential difficulty to locate all business names each time he is in to make deposits (if this is an issue due to your limited name line spaces). While it's ok to do, it's often difficult for a teller to read every dba if you only allow 20 character name lines. Sometimes the client is better served opening one for his larger DBA and using either linked or sweep accounts which are charged on a relationship basis than opening the one large account.

We had a similar situation recently -

Ex. Jane Doe dba Jane's Cakes dba Jane's Cake Delivery. She wanted to open an account for Jane's Cake Delivery, so we set up the account as Jane's Cakes dba Jane's Cake Delivery. We then listed in the notes compartment authorized signers and their position with the company. Then we imaged all related ownership documents - 2 negatives we saw to listing all of the DBA's:
1) Mass confusion would be created on the front line
2) System doesn't support that many business names

So how would you hanndle conclusion 2 - our system being unable to support that many names?

I know the example you've given is hypothetical, but using the names you've selected, the two business names are so close I don't think I would have worried about adding the "Delivery" title.

But the bigger issue is whether banks should allow customers to run multiple sole proprietor (SP) businesses through one account. Quite aside from the fact that the customer may find it more convenient (one deposit, one checkbook) is the fact that the customer is likely avoiding (by design or good luck) paying multiple service charges to your bank.

The other big issue is consistency for your teller and other staff. If you tell them to accept checks only into accounts with consistent names, how well do you suppose they'll handle the exception that multiple SPs in one account will present?

I needed to bump this one, with a slight variation. One of our branches was asked to set up an account with one corporation having multiple LLC's - all using the same EIN. I'm concerned about endorsements, ownership of the Corp and the LLCs (I'm assuming the ownership is the same for all, but if it's not, that would be a problem), but don't like the thought of it at all. According to the branch: "This is the way they have been told to set it up for protection. If a customer in the 'A' LLC wants to sue them, then they can only sue on the one home they are renting and it will protect the rest of his business."

Not sure what the "home" issue is - I'm more concerned with the multiple names. Help!

I can't think of any instance where more than one LLC would be using the same tax ID number. These should be totally separate entities, along with the corporation. A corporation may have more than one d/b/a, but not an LLC.

BBoyd, a corporation can own an LLC. An LLC can be a disregarded entity for income tax purposes, but still retain its legal characteristics of limiting the owner's liability.

Thus, I would very guardedly suggest that what they are doing is possible, but I would call the attorney who drafted the LLC papers and ask for an explanation in lieu of requiring a unique EIN from each. If the attorney sounds like she knows what she's doing, then I would see if the bank's CPA would verify the technique. (I do not take advice from the other guy's lawyer - it's a good rule.)

If I form an LLC as a solely owned LLC, I'm able to use my own SSN. If I form 3 more LLCs as a sole owner, wouldn't I still be able to use my own SSN? Not that I'd want to, but I'm thinking I could.

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I do not take advice from the other guy's lawyer - it's a good rule.)

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Agreed! Especially because they always seem to think they know what's best for the Bank.

I'll ask the branch to get more information from the customer and move cautiously forward. Thanks for your insight.

If the IRS will qualify your LLCs to ignore their separate existence, you can do so.