We have always styled accounts opened by property management companies for their clients as follows:

(Property Legal Name) by
XYZ Property Management Inc as Agent

We use the TIN of the property. We've had numerous legal opinions from attorneys all telling us this was kosher. Both from an FDIC coverage standpoint, as well as a BSA perspective since we know who the benefical owner of the funds is, even if they don't have access to the funds.

Now we've gotten another opinion from an attorney who believes that we should open the accounts in the name of the management company only, use the TIN of the management company, and not reference anywhere in the account styling the name of the actual property owner. That just seems shady to me.

We have property management accounts styled in the name of the property management company using their TIN. However it state the customer the funds are for - is XYZ property management Inc for ABC Apartments...... This wasy we know our customer - XYZ Management and they can identify the funds for their clients.

You mean a written opinion or something off the cuff?

a written opinion

For several reasons based on UCC and BSA considerations as well as teller training, I agree with the advice you received the first time. However, I don't know what alternative rationale this lawyer offered and, accordingly, cannot second guess it.

I suggest you go with the opinion of whoever it is that would represent your bank in court.