The husband of a long time customer of the bank, is using her account to deposit large dollars in postal money orders, cash, his social security check and wires for services he provides. The money is then Paypal'd out. We have no idea of the source of these funds. Her paycheck is an ACH not in questions. We have been filing SAR's for a year. Should we leave the account open?
I have an existing Rep Payee account. Social Security has now assigned a new Representative. Can we use the existing account and simply change the name to the new Rep Payee, or do we have to start a new account?
We have a customer that receives SSA on the 8th of the month. This customer died August 8th, the same day her Social Security went into her account. Do I have to send the money back to SSA? Everything I read says if they die before the deposit then I must return, but nothing about the same day.
We have a potential new customer who does business as a scrap dealer (appliances etc.). He receives checks made out to the name of his business. Does he need to have an account titled with the business name or can the checks be deposited into an account in his name, since it is a sole proprietorship and does not have a federal tax ID for the business? How should sole owner accounts be set up?
What are the proper procedures to CIP for an attorney-in-fact (AIF) under a power of attorney? My question comes from an instance where we have a CIP grandfathered Amish customer and they would like to add someone to their account that doesn't have a TIN and refuses to get one. They went to an attorney to get around the CIP restriction and made him an AIF so he wouldn't have to go through the normal CIP process. Is an AIF considered a customer under 103.121?
What are the risk of setting up a Qualified Income Trust account for the financial institution?
We have customers who have social security checks for dependents made in the following manner: "John Doe For Jane Doe" wherein in some cases the dependent is either a child or disabled person. I argue that these checks are payable to "John" as he is the first payee, and "Jane" is not actually a payee. Therefore, the check should be negotiable by John, or depositable into an account held solely by John. My FI has recently instituted a rule requiring these types of checks to be deposited into a) a UTMA account for "Jane" b) a Rep-Payee account for Jane or c) an account held solely by Jane. As in many cases Jane is either a minor or disabled, I believe forcing an account to be opened under her name to be irresponsible banking. I would like to know the guidelines for negotiating a check made either to "John Doe For Jane Doe" or "John Doe For the Benefit of Jane Doe"
Do we need to run OFAC on a newborn baby whose mother or father have opened a savings account for the baby? We do have the Social Security number for the newborn.
When opening an account with a rep payee, what is the correct way to title the account and who would be considered primary account holder?
When we have a non-profit organization our bank titles it like "Jane Doe D/B/A as Girl Scouts Troop 55" and uses Jane's Social Security number. Where I worked at before titled accounts in the form "Girl Scout Troop 55" and used their own tax number. Can accounts be styled two different ways?