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#1877645 - 12/11/13 02:37 PM CTR Item # 20 regards to Club Accts
Ellie Mae Offline
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Joined: Apr 2008
Posts: 4
Kentucky
What form of identification could be used here in regards to identifying clubs accounts? Our CIP practice is to ID the authorized signers on the Club. They do not have to file with SOS and we do not know of any other identification you could use here. The EIN is already listed on the CTR. This is in regards to cash deposits. Your thoughts would be appreciated. Thank you.

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#1877893 - 12/11/13 09:01 PM Re: CTR Item # 20 regards to Club Accts Ellie Mae
NE Wx Forecast - Frosty Offline
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NE Wx Forecast - Frosty
Joined: Mar 2011
Posts: 442
SE, Nebraska
Ellie May,
With it's own EIN I'm assuming the club has it's own legal docs used for CIP verification. As the owner of the account, the "club" would have the transaction conducted by someone on it's behalf (checking blick 2C), and the "Entity" block would be checked. The conductor of the transaction would have block 2B checked (even if they are the "owner" of the club). Most owners are listed as Authorized signers on their business accounts. For block 20 (assuming the club exists as an entity) you would list whatever legal docs you have on file (in the "Other" block). The conductor would list the standard verification doc, usually a Driver's license in his/her own block 20. If the Club is listed with a person's SSN, then treat the club like a person and file the CTR on the owner. Block 8 would have the Club name information. In this case assuming the conductor is the owner of the account, you would check block 2a. Most club accounts have a SSN, so your relaying the EIN info is a little different and causing your confusion. If the club is it's own entity treat it like a business.

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#1877937 - 12/11/13 10:25 PM Re: CTR Item # 20 regards to Club Accts Ellie Mae
BrianC Online
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BrianC
Joined: Nov 2004
Posts: 6,323
Illinois
Many clubs are not formally organized. For example, my mom's stitching club may have obtained a tax ID number so they can segregate club dues, but the did not register with the state. Since you most likely don't have any documents identifying the club, you will simply check the unknown box.
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