Well, it all comes down to the definition of an account. Do you think they are establishing one? If you have doubts, call your EIC and have a chat with them.
(a) Account. For purposes of Â§1020.220:
(1) Account means a formal banking relationship established to provide or engage in services, dealings, or other financial transactions including a deposit account, a transaction or asset account, a credit account, or other extension of credit. Account also includes a relationship established to provide a safety deposit box or other safekeeping services, or cash management, custodian, and trust services.
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