Many of our commercial clients originate ACH files and some transactions get returned for insufficient funds, etc. When an ACH transaction is returned to us, we charge it back to the client’s account, much like we do for returned checks. We have a couple of clients who have asked for an individual ID to appear on our ACH Return Notices, along with appearing on the transaction itself (though DDA and/or Online Banking history), and appearing on the DDA statement. We have a procedure in place that stops this information from printing on the original ACH transaction for consumer clients. Many of them complained, since this field may contain social security numbers. There is no regulation on what has to appear in this field. It may contain a SS number, but may also contain other information. I have seen a mix of things in this field ranging from a blank field, to a person’s name, to a string of numbers and letters that do not mean anything to me. Basically, we hide this field from consumers due to their complaints. The situation I am asking about is slightly different, but I would still like to confirm with you that there are no regulatory or privacy issues. For the custom we are getting ready to ask for, it will show the information that is in this field, it will show it on the actual return notice, it will print it on the statement, and will also appear through DDA and OLB history. The difference here though is that the client who sees this information on his return notice and on hus statement is the same client who populated that field, so I do not think it will be an issue, since it is information that the client provided to us originally, and that he already has access to it, but I wanted to double check before we get too far down this road.
The bank has received a levy for a taxpayer. The name on the levy is styled as: John Doe DBA Doe's Auto Sales. The tax id number on the levy is an EIN, not John's SSN. We do not have any accounts for the business, but we do for the owner, in his social security number. Does the levy on the business extend to his personal account since it is a DBA?
We have a person who wants to open a checking account. She gave us a Mexican Passport and a credit card as ID. She has a Social Security card. We asked her if she has any US ID and she gave us a US Visa that is valid for one year. Can we open the account for her?
When you are opening a Miller Trust account or qualified income trust, whose social security number do you use to open it, the beneficiary's or the trustee's? Should the trust have its own TAX ID number?
We have an attorney who wants to open an escrow account; however, the funds are from an estate that is being contested. He wants to open the account with the deceased's SSN. Should he not have to get a tax ID number?
If a bank relies on an automated ID verification system for both CIP and red flags compliance and there are red flags associated with the name, date of birth, or social security number that go unresolved, are these CIP violations as well as violations of the bank's identity theft program? We only use the system to verify the identity of customer’s who are new to the bank.
It’s my understanding that for CIP of a US citizen a driver’s license number is not a valid ID number, but a that a TIN is required as an ID number, correct? If so, where can I find the citation/rule?
Our credit union has always opened trust accounts and allowed the trust to be listed with the trustee's social security number if a TIN was not assigned. Someone now told us we should let the ownership only reflect the trustee's with their respective SSNs if we have no tax ID number. Is this true?
If an irrevocable trust is set up whom do we CIP, the trustees, the beneficiaries?
I was told that we can accept a cedular card as ID for CIP purposes. What exactly is a cedular card?