Currently, when we receive a IRS Tax Levy, we look at the Social Security Number or EIN Number on the Levy and the name. We then research this information in our system to see if they have an account(s) and what funds are available to hold on the day the Levy is presented. We base this on the Name and EIN or Social Security Number provided on the Levy. My question is if we perform our search and determine that the primary name and Social Security number on the account does not match the Levy but the person the Levy pertains to is a signer or secondary owner to the account (Joint Account), should we hold those funds? Should this be done even if it's a Business, Minor Account, IOLTA, Escrow etc.? I would think consideration should be given to the relationship the person upon whom the Levy is presented has to the account.
We have several attorneys who maintain IOLTA accounts with our bank. They all use the same tax ID and their transactions aggregate on the large cash transaction report. If they are acting independently, would we still need to aggregate the transactions for CTR reporting?
Who is the customer for CIP purposes on an IOLTA account and how should the account be styled?
For an Interest on Trust (IOLTA) account, who would the beneficiary be for CTR purposes? The attorney or law firm or the client(s)?
What can you tell me about a trust account, similar to an IOLTA account, that is used by real estate or property management companies to hold renters' security deposits. The funds in this account cannot be commingled with operating funds and my understanding is that they can be interest bearing. My concerns lie in the account titling and what happens to the interest.