for a business account, you would get the tax id on the business and verify it.
How about the signers on a business account? Are we required to get the tax IDs on signers??
Thank you.

No. You are verifying the existence of the business. You should also request copies of their legal FILED documents, proof that they exist in the eyes of the state.

This is what I love about CIP. We have to identify our customers that are individuals, but we do not have to identify business owners. Sure, we get incorporation documents, licenses, etc. to verify the existence of the entity, but does anybody really identify those people when they obtain incorporation papers, licenses, etc.? In some states, anybody can set up a corporation over the Internet and all you have to do is provide minimal information to an agent, and most importantly, a check. Scary isn't it?

Quote:

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for a business account, you would get the tax id on the business and verify it.
How about the signers on a business account? Are we required to get the tax IDs on signers??
Thank you.

Post Extras:
jcrump
Junior Member



Reged: 08/05/02
Posts: 27
Loc: Texas
Re: signers and tax ID
#141555 - 12/17/03 05:52 PM Edit Reply Quote



No. You are verifying the existence of the business. You should also request copies of their legal FILED documents, proof that they exist in the eyes of the state.

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Maybe there is some confusion here, and the experts can chime in and clear it up. The purpose of the CIP is to identify customers. We all know about identifying individuals, but there seems to be some confusion about non-individuals. I have taken the position that we get all normal documentation to identify the business, and we identify the principals of the business using standard identification procedures. But, we see no need to verify the identity of all of the individual signers who have no ownership interest in the business. Are we on the right track?

Retread,
You are on exactly the right track. The "customer" is the entity, the law requires you to obtain the name, address and TIN and use documentary or nondocumentary verification to establish identity.

My opinion is that identifying the signatories is a "best practice," but it is definitely not required by CIP. I would be less inclined to run principals who are not authorized signers through a full blown CIP process. The latter observation would change if it is a "high risk" business.

I was just handed a request to open a NOW account for an out-of-state trust. (There is no question that I will open the account in that it was handed to me by my boss.)

I am thinkin non doc. He will send me trust agreement. I am having no luck pulling up on-line verification of the trust because it is in Nebraska. Why do some states want to make things so difficult?

I OFAC'd w/ the name & TIN. Not a problem.

Any help out there?