Pre-CIP Accounts

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Question:

Is there an IRS or other regulatory penalty for a bank not having a proper EIN for a business account on "pre-CIP" accounts? If so, where can this information be found?

Answer:

You are still required, under BSA regs, to maintain a list of such accounts. If you do that, there's no penalty because the IRS doesn't care, since you don't send 1099s or 1098s on these accounts.

First published on BankersOnline.com 9/22/08