In the past, we have allowed grandparents to open savings accounts for their grandchildren with the grandchildren being the primary owners and the grandparents as secondary. They would have the child's social security number. They would sign the child's name,(child is unable to sign due to age). Relative to CIP purposes can this still be done?
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?
When a parent opens an account for a minor and uses the minor's Social Security number, but only the parent signs on the account, is the ownership of the account joint or individual?
We open renters' security deposit trust accounts. Do we need to verify the tenant's ID and check his/her name against the OFAC list? I know that for the landlord we have to do this. Is it sufficient to just keep the W-9 on the tenant?
At our bank we open Escrow Trust Accounts. Our customer is the Escrow Company and they are opening accounts under their client's name and social security number as a trust. We are only obtaining the name and social security number of these individuals. Are we obligated to ask the escrow companies for more information on their clients, such as their address and date of birth and identification?
What can you tell me about a trust account, similar to an IOLTA account, that is used by real estate or property management companies to hold renters' security deposits. The funds in this account cannot be commingled with operating funds and my understanding is that they can be interest bearing. My concerns lie in the account titling and what happens to the interest.
It isn't a regulation yet, but the message is clear.
Question: At our Credit Union we have four ATMs that are serviced by an armored car company.