We have a customer (a funeral home) that would like to open numerous "pre-need" accounts for their customers. The owner of the funeral home has his customer's name and social security number, but in a lot of cases, no identification (some of his customers are in nursing homes and the accounts are requested by family members.) The accounts would be titled "ABC Funeral Home FBO John Doe," using the person's SS#. Our question: To comply with the USA PATRIOT Act and our CIP policy, how do we positively identify the customer if they do no personally come into our bank AND if the funeral home does not have identification on file for them to present to us at the time of account opening? Since the account is set up in the name of the funeral home for benefit of the customer, as long as we positively identify the funeral home as a business and the funeral director as the signer of the account, have we met the requirements for positively identifying our customer? We hate to refuse to open the accounts but we don't want to violate our own CIP policy which states that all accountholders must present valid ID in person. Help please!
If a sole proprietorship account is styled Jane Doe dba Jane's Jeans, we would use Jane Doe's SSN for the tax ID. If Jane's Jeans has its own EIN, should the account be styled the same? I always understood the first name on the legal title should match the tax ID number.
I want to make sure that the account styling is correct. I have 2 different LLC's and they have joint interest in a piece of real estate and they want an account styled XYZ LLC ABC LLC. Also, they want XYZ LLC tax id to be the primary. Is this the correct styling and if not what should it be?