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#907320 - 02/20/08 04:10 PM CIP TINs for Non-U.S. Persons
Norrie Offline
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Joined: Feb 2008
Posts: 67
For purposes of CIP, is a "TIN application" acceptable at account opening for a non-U.S. person?

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#907430 - 02/20/08 05:29 PM Re: CIP TINs for Non-U.S. Persons Norrie
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
No.
You have to get the passport.
The fact that they have applied for a TIN is just informational to you.

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#909898 - 02/25/08 06:51 PM Re: CIP TINs for Non-U.S. Persons MagicCity
Norrie Offline
Member
Joined: Feb 2008
Posts: 67
Is a W-8 form (U.S. tax withholding) acceptable as CIP identification for a non-U.S. person?

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#910077 - 02/25/08 09:29 PM Re: CIP TINs for Non-U.S. Persons Norrie
Dallas Fan Offline
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Joined: Feb 2008
Posts: 219
RIC
No, that would be insufficient.
If the individual is a non-U.S. person, one or more of the following: a U.S. taxpayer identification number; a passport number and country of issuance (unexpired); an alien identification card number; number and country of issuance of any other (unexpired) government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.

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#910108 - 02/25/08 09:50 PM Re: CIP TINs for Non-U.S. Persons Dallas Fan
Norrie Offline
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Joined: Feb 2008
Posts: 67
That was my thinking but I've been receiving some push back saying that TINs are not required for Non-Resident Aliens if they are not engaged in a trade or business in the U.S. and that is proved by the W-8 form.

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#910122 - 02/25/08 10:02 PM Re: CIP TINs for Non-U.S. Persons Norrie
Anonymous
Unregistered

TINs, by law, are not required for NRAs. They can have a TIN, but if your policy allows, they don't have to have a TIN if they have any of the four things WyoRockies stated above.

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#910128 - 02/25/08 10:08 PM Re: CIP TINs for Non-U.S. Persons
Norrie Offline
Member
Joined: Feb 2008
Posts: 67
In your opinion, does the W-8 form qualify as one of the four items listed by WyoRockies? (I have never seen a W-8 form.)

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#910139 - 02/25/08 10:24 PM Re: CIP TINs for Non-U.S. Persons Norrie
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
CIP requires an identifying number as one of the 4 pieces of information that you are required to obtain. Having the customer sign a W8 certifying that they are not a US person subject to US taxes is 1 thing, but it has nothing to do with CIP. Your policy should state what is required for a NRA (most likely a passport).

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#911346 - 02/27/08 05:20 PM Re: CIP TINs for Non-U.S. Persons devsfan
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Joined: Feb 2008
Posts: 219
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I agree with devsfan. I apologize for any confusion on my previous answer. The TIN is one piece of information that a non US person might, but not always have but for identification purposes I would want the following:

Under normal circumstances, the bank shall examine an identification document evidencing the nationality or residence of the individual and containing a photograph or similar safeguard. : Acceptable identification documents would include an unexpired government-issued driver’s license, passport, or an unexpired government-issued identification card.

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