Reg CC states: An account is not considered a new account if each customer on the account has had, within 30 calendar days before the account is established, another account at the depositary bank for at least 30 calendar days.
Our scenario. New business opens new business account. Authorized signers have had deposit accounts personally open since 2014.
The customer is the LLC and the LLC doesn’t have a transaction account that’s been open for 30 days or more. The LLC’s new account is a new account for purposes of the regulation.
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John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8