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Phase II Exemption - Same Owners, Different TIN

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I am currently doing the annual review of Phase II exempted entities and I found that a previously exempted business account is now conducting cash deposits to a different account, opened in September, 2006, with a different TIN. The names on the accounts are the same and two of four authorized signers are on both accounts. Can I exempt the new TIN because of the existing exemption status for the old TIN, or do I have to wait for September, 2007?

How can one entity have two TINs? There needs to be a little more due diligence conducted.

First published on 7/23/07

First published on 07/23/2007

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