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Exempting A Customer With Multiple Locations & EINs

Answered by: 
John Burnett

Question: 
We have a customer who is in the car wash business and been with the bank 18 months. He routinely makes cash deposits over $10,000. We would like to exempt him. However, as he opens new locations, he puts each one under a new TIN. For the new locations (new TIN and new account number), do we have to wait 12 months on each before we could exempt the accounts?
Answer: 

Since each location has a separate EIN, my guess is that each is a separate entity. Rather than establish one business with multiple locations, he has established multiple businesses each with one location.

I believe you have to treat each business separately for purposes of Phase II exemptions.



First published on BankersOnline.com 06/16/03

First published on 06/16/2003

Filed under: 
Compliance
Filed under compliance as: 
EIN
TIN

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