06/18/2012
A subsidiary of our Bank wants to offer Non-Traditional Banking products to customers who may not have a ITIN or SSN. These products will be non-interest bearing accounts. Can we open such accounts without an ITIN/SSN and what policies/procedures should we follow?
03/19/2012
We have a customer that has a Business DDA with the first name line his own, tied to his own social and the second name line his dba tied to an EIN. If he deposits over $10K cash into THIS business account how is our CTR to be completed? Our "tax" line is tied to the DBA and its EIN. Please advise.
12/05/2011
Is there any regulation that requires obtaining/retaining a copy of a social security number and drivers license for any and all checks cashed for a non-customer, whether it is an on-us check or a check from a non-customer to an existing bank customer? We do understand the need to pull OFAC on all transactions that involve a non-customer no matter the amount of the check. It is very time consuming to make copies of IDs and the checks. Are examiners going to the extreme? If we check identification, it seems that with the OFAC that should suffice. Are all banks required to do this now?
08/22/2011
Can an UTMA be opened with a ATIN (Adoption Taxpayer Identification Number) until the Social Security Number is issued? If so, are we required to withhold?
07/18/2011
Levy-related: The IRS provides an alternative on Form W-9 for individuals to provide an SSN or an EIN. I believe FIs are required to obtain an SSN for an individual as her/his TIN and so the issue is not applicable from an FI perspective. As a non-FI in a trade or business receiving W-9s where an individual has opted to provide an EIN rather than an SSN, a levy may identify an individual by SSN such that we cannot guarantee that the levy is for the same individual (two people with the same name). Giving the volume of levies that FIs deal with, I am hoping you may have guidance regarding the identification of the taxpayer in the circumstance I have described.
04/18/2011
We have a new teller that cashed a $11,500 check for a non-customer. She verified the customers ID and got all the required information for the CTR except for his SSN. We have called the individual and he refuses to give us the SSN. How do I proceed with the CTR and is a SAR necessary?
04/11/2011
I have a question with regard to Reg CC and the ever changing environment of delivery methods and new accounts. The local tax firms such as H & R Block, Joseph Hewitt, etc. are providing tax refunds via a debit card. The way I understand from a manager of H & R Block, the tax forms are submitted to the IRS for review. Once the IRS approves it and releases the funds to H & R Block, the funds are then captured on a secured server and transferred to the debit card. This would be done by H & R Block. The customer gets this card in the mail. Their PIN is the last 4 digits of their SSN. Their customer is told they can access the cash at any ATM. If we have a new customer to the bank who wants to open an account, and they present one of these debit cards to have the balance on their card as their opening deposit, would that transaction be considered a Next Day Item/Electronic Payment? For us to access the funds, we would have to process it like a Cash Advance, typically a type of transaction done with a credit card. I am thinking it would be an electronic payment, even though there is some manual process to it. Would that be correct? I know the debit card is a substitute for the check, but again to access the funds, we have to go through an electronic medium to get them. We would get an approval code on the machine and record it in our paperwork. With a Cash Advance, once we get that approval, it authorizes our bank to pay the funds. We can then deposit it to an account or give the customer cash. It would be the same process with a debit card.
02/21/2011
Is an EIN required to open an account such as a class reunion account, or is it ok to use the SSN of the signer?
09/27/2010
Have there been any recent regulatory changes which state that an account (CD, checking, savings etc), held in the names of husband and wife jointly, cannot be retitled and placed into a trust? Do these accounts have to be closed and a new account opened? Are there issues we should be aware of due to the retitling? If so, please specify.
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.