Latest Compliance - Sole Proprietorship Topics

Reg E: Is a sole proprietorship a natural person?

07/07/2003

Generally, the definition of consumer is someone using an account for "personal, family or household purposes." However, Reg E simply defines a consumer as a "natural person" [205.2(e)]. When dealing with a sole proprietorship account (e.g., "Jane Doe d/b/a Jane's Flowers," or "Jane's Flowers, a Sole Proprietorship," does Reg E cover the account the account is for a business purpose, but considered to be owned by a natural person?

CTR Beneficiaries: What if the sole proprietorship, the owner, and and authorized signer are all on the account?

03/03/2003

In filing a CTR we have a situation in which a sole proprietorship, the owner, and an authorized signer are on the title of the account. Is it proper to treat each of these individuals as beneficiaries in Section A?

When One Account Owner Wants the Other One Off

07/01/2002

This is a strange situation. We have a business account that we can not find resolutions for. From looking at the signature cards, it would appear that person A opened the account and added person B four months later. At some point in this business relationship, it went sour between person A and Person B. Person B came in and requested we remove person A from the account. We told person B that we had no authorization to remove person A based on person B's request alone. (got this?) We told both of them that they needed to resolve the situation and one possiblilty was to close the account reopen another with the sole person on it. What happened, however, was Person A withdrew funds while Person B wrote checks causing the account to go into overdraft. NOW person A wants to be removed. We say no, not until the account is brought back to zero. Please explain what procedures and/or regulations pertain to removal of names from a business account!

Business Accounts: Authorized Signer Information

05/06/2002

Can you give me any information on authorized signers on a business account?

Definition: MMDA & NOW Accounts

02/11/2002

Could you explain the difference between a MMDA and a NOW account to me?

Can a sole proprietor have a single EIN for several businesses?

11/05/2001

Can a sole proprietor use the same EIN for several business tradenames or must he have a separate EIN for each business tradename?

Establishing a Customer Verification Process

05/07/2001

We are trying to establish a 5 point customer verification process. What are other financial institutions using? I've been told that it is not recommended to simply use social security and driver's license numbers as they are too easy to obtain on the internet.

Privacy Notices: Treat sole proprietors like corporations?

05/07/2001

Can sole proprietors be treated like corporations as it relates to privacy notices?

Know Your Customer Soon - Somehow

10/01/1997