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#1809694 - 05/01/13 01:41 PM Missing TINs
LizzyP Offline
Junior Member
Joined: Jul 2006
Posts: 48
TX
If we have missing TINs on accounts that were opened before October 2003,do we have to send Letters to the customer trying to obtain the TIN information? Can we rely on the history of the accounts for knowing our customer?
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BSA/AML/CIP/OFAC Forum
#1809747 - 05/01/13 02:37 PM Re: Missing TINs LizzyP
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Your bank's CIP should clearly indicate your bank's perspective on existing customers. For instance, do you perform CIP on a pre 10/03 customer who is opening an account today?

CIP directives only apply at account inception. They never suggested that banks were required to do any type of outreach to existing customers to obtain missing TINs. For several years IRS requirements directed banks to go through an annual TIN solicitation regimen, but that only applied to interest bearing accounts.
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#1809770 - 05/01/13 03:00 PM Re: Missing TINs Elwood P. Dowd
LizzyP Offline
Junior Member
Joined: Jul 2006
Posts: 48
TX
Ken, We only request CIP on an existing customer pre 10/03 if we do not have any documentation on file. We are just trying to cover ourselves when the examiners come in for our BSA exam.
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#1809974 - 05/01/13 08:06 PM Re: Missing TINs LizzyP
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,792
Cape Cod
With respect to those old pre-10/03 accounts, you still have to be able to produce a list of those without TINs.
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