We have a non-profit that is updating their signers. We provided a signature card for them to sign. The signature card has the names, social security #, personal information, etc. of each signer. We received a complaint about their privacy rights being violated. Interested to know if anyone has received similar complaints or have a different format where each signer is handled on a separate signature card.

If the signers don't trust the other signers in the same non-profit, then maybe they shouldn't be associated with that non-profit.

Regulation P allows you to share information in order to service an account which you are doing. Also Regulation P applies to consumer accounts, not information collected in conjunction with a non-profit. (See 1016.1(b))

(b) Scope. (1) This part applies only to nonpublic personal information about individuals who obtain financial products or services primarily for personal, family, or household purposes from the institutions listed below. This part does not apply to information about companies or about individuals who obtain financial products or services for business, commercial, or agricultural purposes.

Any accomodation you make to provide seperate documents to obtain account signer information is a business decision.

I would also add that signers on a business account are not considered customers according to the USA PATRIOT Act so unless your board approved CIP requires it, you do not have to obtain social security numbers from business account signers. (Of course, the beneficial ownership certification is another story, but you'd only need a control prong for a non-profit.)

Thank you

I will add that there was no requirement that you obtain the SSNs of the authorized signers on the non-profit's account. And there is certainly no requirement that all the personal non-public information be included on the signature card for all of the other signers to see. Including all that info on the signature card may be convenient for the bank, but I think you can see why some signers might object.

To clarify -- no regulatory requirement to obtain all those SSNs unless the bank has self-imposed that requirement.

We just had this discussion yesterday with our deposit ops team. Signors are not customers, therefore you have no obligation to collect that information and I was confusing the [censored] out of that team.

We are in a situation where we have no written procedure to collect that information but our branches do it anyway. It's nice because during exams, we do not have a NO TIN list to run through, but it's not really a requirement unless you have your own written requirement to do so.