Yes, if the intermediary won't be doing the tax reporting, you will need the SSN/TIN for the owner of the funds. But your customer is the intermediary, and the CIP regulations say that is whom you CIP. Unless your bank's CIP expands that requirement to cover the third party in the arrangement, you don't CIP the owner of the funds.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8