06/07/2010
Is there a certain sequence for state tax ID numbers? Do they start with a certain number per state/county?
05/24/2010
We have an LLC with two members (husband and wife) and they would like to use a Social Security number for the account. In the literature from a recent webinar, it mentions that only a single member can use a Social Security number. We are speaking to the CPA for the LLC, and he is telling us that if the LLC is a "disregarded entity", that a Social Security number is acceptable. Is this correct? If so, what paperwork will we need to comply with all of our requirements if we are to allow this entity to use a Social Security number?
04/12/2010
If we do an OFAC check on our accounts (past 12 months) and there is one account hit, should we send the account name to OFAC? Do we need to find out the transaction of the account?
03/29/2010
For purposes of setting up an estate account, who is considered the customer for purposes of CIP?
02/08/2010
When completing a CTR for a deposit made into an account that reads "The Doe Family Trust," what is the proper way to complete Section A of the CTR? The Memorandum of Trust Agreement states John and Jane Doe are the settlors and trustees for this trust. John Doe's SSN is being used as the identification number for this trust.
01/04/2010
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?
11/09/2009
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?
11/02/2009
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?
10/26/2009
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?
10/01/2009
By FinCEN?s Office of Compliance and Office of Outreach Resources