Answer:
Consider that the attorney or firm opening the IOLTA is your customer for CIP purposes. You need the customer's name, street address and taxpayer ID number. If the account is being opened by an individual attorney (not for his/her LLP, PC), you'll use his SSN and add his DOB.
Most state IOLTA administrators have guidance on how to set up and title the accounts. You'll need to label the account as an IOLTA account in some way to ensure it's fully insured under FDIC rules. Usually, state rules ask that you use the state IOLTA committee's EIN for tax reporting purposes. If the account is held by a corporation, however, you should suppress reporting.
First published on BankersOnline.com 3/01/10
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