09/07/2009
Our credit union has always opened trust accounts and allowed the trust to be listed with the trustee's social security number if a TIN was not assigned. Someone now told us we should let the ownership only reflect the trustee's with their respective SSNs if we have no tax ID number. Is this true?
08/10/2009
I need an opinion. This is about servicing non-customers and aggregating for BSA. We cash on-us checks for non-customers. We also sell money orders to non-customers. Our front end teller system completes an OFAC check prior to completing the transaction and our core database software reports and aggregates all cash transactions by SSN for BSA reporting and for AML tracking. Our new senior management has overridden my opinion that we should always collect a SSN on these non-customer transactions. What they are going to implement is a threshold value for these transactions. No social will be required for non-customer transactions under a certain dollar amount. The OFAC check will still be performed on the non-customer name. I feel that now we will be giving preferential treatment to non-customers where we will be tracking all cash activity on our customers.
07/13/2009
We have a customer born in the US, with a SSN and State ID. He wants to have a debit card with his name in Spanish, as he may travel to Mexico. Are we obligated to do this? Would this violate CIP and BSA requirements?
06/22/2009
Regarding BSA, what are the bank options if a non-customer wants to cash a large on us cashier’s check, but refuses to provide a social security number?
03/23/2009
When completing a CTR for a deposit to a Totten trust account "John Doe Trustee for Sally Doe," who should be indicated as the beneficiary of this transaction on the CTR if John Doe's SSN was used to open this account? If a deposit requiring a CTR is made to a TXUTMA account "Sally Doe, Beneficiary TXUTMA, John Doe, Custodian," who should be indicated as the beneficiary on the CTR when Sally Doe's SSN was used to open this account?
03/09/2009
Can a bank require a non-resident alien to have a Federal Taxpayer Identification number to cash one of our client's checks for over $10,000? If we do not require this information how do we complete the CTR?
02/23/2009
How would we title an LLC using a Social Security number?
01/12/2009
Is CIP documentation required for court ordered accounts such as when minor children receive money from a sale of property and the court orders CDs to be purchased for the minors and held until they are 18 years old?
11/17/2008
Are government agents or law enforcement employees exempt from providing their personal information for CIP when they open accounts?
10/01/2008
By John Byrne, Bank of America