We (the bank) are going to be acting as "escrow agent" - NOT qualified intermediary on a 1031 Exchange account. I know that for CIP purposes the company would be the customer, not us as the bank. But whose TIN would we use?
I have definite concerns about engaging in this type of account and the potential liability. Operationally speaking, how would we set this account up, and with whose TIN, without assuming responsibility as the qualified intermediary?
Please Help. Thanks in advance.
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"I shall permit no man to narrow and degrade my soul by making me hate him." ~ Booker T. Washington