Thread Options Tools
#6016 - 10/29/01 02:24 PM "No TIN List"
Richard Insley Online
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,007
Toano, VA
What's been everyone's recent experience with examiner requests for the so-called "no TIN list" required by the BSA regs? If properly maintained, this list should contain the names/aliases of terrorists & other foreign visitors who have opened deposit accounts, but who do not have a TIN.
_________________________
...gone fishing.

Return to Top
General Discussion
#6017 - 10/29/01 02:44 PM Re: "No TIN List"
La. Lady Offline
Diamond Poster
La. Lady
Joined: May 2001
Posts: 1,873
We have maintained this list. We print the list quarterly and have our customer service area "work" the accounts. They contact the customer and document responses. Examiners have asked to the list each time that they have come over the last 3 years.

_________________________
Riding the waves of change.....2014

Return to Top
#6018 - 10/29/01 03:19 PM Re: "No TIN List"
SusyG Offline
100 Club
Joined: Oct 2001
Posts: 120
What "NO TIN LIST"? We cleared this up a couple of years ago and absolutely do not open an account without a TIN. NO TIN, NO ACCOUNT. This has not been nearly as hard to enforce as we thought it was going to be. If the customer has a problem with it, they can go across the street and let that bank deal with the headache.

Return to Top
#6019 - 10/29/01 03:28 PM Re: "No TIN List"
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
OCC generally reviews our "applied for" and "alien" reports and supporting documentation. We open accounts on a regular basis for customers who have applied for, but not yet received, EINs. These are usually new businesses and estates. Examiners also look to make sure we sent our due diligence letter within 30 days requesting the TIN, and make sure we are withholding if we don't have a valid W-9 or W-8BEN on file.

We are also still trying to work through older accounts we have acquired through mergers and acquisitions with erroneous default TINs (such as 9's). Just when we get close to having them cleaned up we bring on another bank. Great job security, huh?

[This message has been edited by Brenda Canterbury (edited 10-29-2001).]

_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

Return to Top
#6020 - 10/29/01 03:54 PM Re: "No TIN List"
Al Miller Offline
Diamond Poster
Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
Brenda, why wait for an EIN on new businesses and estates. One can be obtained by phone. Complete an SS-4
http://ftp.fedworld.gov/pub/irs-pdf/fss4.pdf

Call in the information and receive the EIN by phone. The signed SS-4 needs to be mailed or FAXed to IRS within 24 hours, but your new accounts representative can do that for the new customer.

------------------
Al Miller, CRCM
Fremont Bank (CA)
(510) 790-5825
(510) 505-5211 FAX

Opinions expressed are my own and not necessarily shared by my employer.

_________________________
Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

Return to Top
#6021 - 10/29/01 04:09 PM Re: "No TIN List"
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
IRS in Memphis indicated we should not utilize Tele-TIN any more. They have instructed us to fax in SS4 forms.
_________________________
Life without Jesus is like an unsharpened pencil - it has no point.

Return to Top
#6022 - 10/29/01 06:02 PM Re: "No TIN List"
Maria Offline
Platinum Poster
Joined: Apr 2001
Posts: 502
Sylacauga, Al, United States
We have not had an exam since I assumed this position, although we have one scheduled shortly, so I can not comment on what the examiners are requesting.

I would like to comment though on verification and certification of the TINs. I performed an audit and was suprised to find that new accounts staff did not realize they needed to have verification and certification on TINs by the customer. This could be a high penalty situation per account. It took much time and research to clean up.

Point being, sometimes we take for granted that employees that have been in banking for a long period of time have been exposed to training that we personally may have received. This is not always the case.

Also, not only should the missing TIN report be reviewed, but also the TIN/CIF not matching report should be reviewed.


Opinions are mine and not my employer


Return to Top