We received a levy, and the customer has a CD that is pledged as security on a loan. Does our perfected security interest trump the levy or do we have to exercise our right of offset (cash the CD and pay the loan) in order to not be required to satisfy the levy with it? Secondly, if a customer we get a levy on has both deposit accounts and loans, do we have to exercise our right of offset or does simply that right trump the levy. Can the bank say there are no funds available to satisfy the levy, even if the right of offset is not actually invoked, assuming the customer owes more in loans than is in the deposit account?
For purposes of setting up an estate account, who is considered the customer for purposes of CIP?
We have a sole proprietorship account opened with the customer’s social security number. The customer wants to change it to an LLC account, do we need to required them to provide a TIN or EIN?
We have a customer who has documentation to support that he is a non-resident alien, however he meets the substantial presence test and has a "For work purpose only" social security card. Would this customer be considered a resident or non-resident alien for bank purposes, and can we use the social security card for CIP documentation?
We had a CTR returned to us for a name/TIN mismatch. The CTR was filed on a charitable organization. We have conflicting information in our records pertaining to the TIN. We have not been able to get in contact with the individual who opened the account or the charitable organization itself. Time is running out on getting the correction back to the IRS. What are our options?
Can a partnership report under one of the partner’s social security number, rather than filing for a EIN?
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 to file a CTR for a cash deposit to an account of a single member LLC that uses its member's Social Security number instead of an EIN. Should we use the 2008 DBA ruling from FinCEN as a "go by" to complete the CTR?
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?
Reports Filed under the BSA Critical to Largest Medicaid Fraud Case in the Nation