Skip to content

Phase II Exemption - Same Owners, Different TIN

Answered by: 

Question: 
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?
Answer: 

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

First published on BankersOnline.com 7/23/07

First published on 07/23/2007

Filed under: 
Filed under security as: 

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics