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#2109316 - 12/01/16 05:37 PM new account hold for DBA
complyorelse Offline
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Joined: Nov 2007
Posts: 442
U.S.
We have an existing customer who opened a new account for a new DBA. Would this account be eligible for a new account hold? We did create a new CIF for the DBA but I don't know if a DBA is considered a customer, for Reg CC purposes, since it is using the same SS# as the customer who opened the account. I don't believe the regulation provides a definition of a customer even though that is the term used in describing what a new account is/is not.

Thank you.

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#2109319 - 12/01/16 05:57 PM Re: new account hold for DBA complyorelse
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,628
Galveston, TX
An assumed name certificate does not make it a different customer.
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#2109331 - 12/01/16 06:46 PM Re: new account hold for DBA complyorelse
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
(tt) Customer means a person having an account with a bank.

As indicated, "rlcarey" and "rlcarey DBA Super Tex" (apologies to AJ Foyt) are still just one customer. The same would be true for a business entity with a DBA.
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#2109368 - 12/01/16 09:06 PM Re: new account hold for DBA complyorelse
complyorelse Offline
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Joined: Nov 2007
Posts: 442
U.S.
Great. Thank you for clarifying.

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