08/22/2011
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.
05/30/2011
Can a grantor on a trust change her social security number to a TIN without closing that account?
01/24/2011
I am opening a guardianship account. Do I need IDs from the owner (ward) or just the guardians. I do have the court papers.
01/03/2011
I have a PLLC opened with a husband and wife. It is in the wife's social security number. They both want to leave that way. Can they do this?
10/25/2010
Mary and John have a joint business checking account. John also has an individual checking account. John makes a cash deposit of $6,000.00; later that same day, Mary makes a cash deposit of $5,000.00 into the joint business account. A CTR gets generated based upon the cash aggregated amount of $11,000.00 for John. Does Mary have a right to have a copy of that CTR? I am worried that if she does, she now can see personal information such as SSN, birthdate etc. Please advise.
10/04/2010
Regarding automated telephone banking systems, customers can currently inquire (get account balance and info) by phone with their account number and last four digits of their SSN. If they want to transfer funds between their accounts, they must complete an application. My bank wants to give automatic access to transfers too. I'm concerned about Reg E issuing access device rules. Is calling the number and following the steps, "requesting" the access? We have new operations personnel who say all banks do this automatically. Other banks don't have customers fill out a form or call and talk to someone, it is all done through the automated phone system. Does this comply?
08/23/2010
Upon verifying the SSN of a new customer's information, it was found to be that of a deceased person. Do we need to fill out a SAR on this?
08/09/2010
We have a customer who runs an insurance agency titled under his name,(John Doe, Agent). If he wants to open an account so that the premiums he collects on behalf of certain companies can be swept out by ACH on a regular basis, how should it be set up? He is a sole proprietor; should he have access to the funds, TIN or SSN for the account? He wants "trust account" in the title. What if he receives an IRS levy, could these funds be taken? Please let me know the appropriate way to set up this account type.
08/02/2010
While cashing a check issued by its customer to a third party, is it mandatory for the paying bank to obtain the Social Security Number of the payee apart from photo ID details? If not, and if the transaction results in filing a CTR, what is the recourse?
07/12/2010
Recently in dealing with a non-resident alien, an ITIN was presented at the time of account opening. After researching on the irs.gov website and calling the IRS, I was told that an ITIN can only be used to file a US tax return. It is not to be used for any other purpose, including opening a bank account. In your question and answer page about non-resident aliens it mentions and ITIN can be used . Please clarify.