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#2033140 - 08/12/15 01:50 PM CTR Identifying Information
Linkpars Offline
100 Club
Joined: Jan 2007
Posts: 179
Kentucky
A customer owns a car lot and he is the sole owner, however when he opened the account he was incorporated. A CTR came into play and when verifying the ID info, we noticed that the company was showing as dissolved on the state website. The account was opened prior to CIP rules.

Question is, can we use a business license as the identifying information, the business tax ID # or use his TIN since he is the sole owner?

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#2033153 - 08/12/15 02:04 PM Re: CTR Identifying Information Linkpars
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
If we opened an account as incorporated and later discovered the corporation was not operating lawfully under state law (registration expired), we would warn them to correct that or the account would be closed in so many days. They could always switch over to a DBA account, or go update their Sec State registration. For this CTR, I would probably use what you had on record to open the account.

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#2033158 - 08/12/15 02:07 PM Re: CTR Identifying Information Linkpars
Linkpars Offline
100 Club
Joined: Jan 2007
Posts: 179
Kentucky
Dasiy, let me ask you this. If we use the information we have which is expired, should we have documentation in our file to show where we requested or called the customer about correcting this matter. You know for examiner purposes?

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#2033180 - 08/12/15 02:27 PM Re: CTR Identifying Information Linkpars
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
While I have had examiners request supporting docs for CIP on new customers, I have never had one question what we had for ID on a CTR. So, I would not worry about that myself. I would just put a note to myself on my Outlook calendar to follow up in whatever time period we gave them. If that is too informal for you, then perhaps you have some kind of CIP exception document you could add them to.

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