We have an account ABC Bail Bond Company, LLC/ County Sheriff, Trustee. The account is used to hold bail money in trust for the bail bond company and only the county sheriff has transactional authority over the account.
There is a new sheriff in town so the signature card needs to be amended to add him as a signer; however, Sheriff does not wish to provide CIP information to make this happen. If this were a county account it could probably be considered exempt from beneficial ownership and CIP, but since this money belongs to the bail bond company, it would seem that BO and CIP could not be avoided and the Sheriff would meet the control prong.
If we require him to provide CIP, then he just wants to close the account. However, that can't happen since he does not have transactional authority. I suppose an option would be to cut and official check payable exactly as listed on our system and then its the next bank's worry.
Anyone have thoughts on this situation? I appreciate any comments you have!