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BankersOnline.com BOL Compliance Gurus

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Question: 
We've always had the substitute W9 on our deposit agreements. Should we also be certifying TINs with <i>loans</i>, too?
Answer: 

While you are required to obtain the proper TIN on your loans, there is currently no requirement that the customer certify the TIN. Makes sense when you think about it because the customer is the one that has the most to gain from ensuring the his TIN is recorded correctly because he will want the interest he paid to be correctly reported to the IRS. See paragraph 5 of the 1098 instructions for verification.

First published on 01/01/2001

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