Skip to content
 

Latest Compliance - SSN Topics

Expiring W-8 Certification-Secondary on Account

06/17/2013

We have a foreign individual whose W-8 certification is expiring the end of 2013. This individual is secondary on the account; interest is being reported under the primary owner's SSN. What are the implications, if any, if the foreign individual does not sign the W-8 certification?

Responsibility In Determining Person Legal Status

04/22/2013

Where does the responsibility stop for banks in determining a person's legal status? We know by looking at the SS Card its a fake but yet on Chex Systems and Credit Reports the SSN and Name of customer match up. How do we deny a person based on a fake ID when they've gotten away with it for so long? Do we have the obligation to police the legal status of a customer?

POD Beneficiaries Who Are Not US Citizens

03/11/2013

An account holder passed away and named POD beneficiaries who are not US citizens and do not reside or work in the US. No relation to the US other than a family member left them money. The beneficiaries each want to take their share of the account however do not have SSN or ITIN. What do they need to do? These are non IRA funds.

Remove Name of Deceased from CD w/o Penalty?

02/11/2013

A spouse dies on a jointly owned CD. Can the name of the deceased be removed and the CD continued to maturity? OR do you let it mature and then change the ownership? Is there a penalty for changing only the name due to the death?

ITINs Required for Non-Resident Alien Accounts

01/14/2013

Currently, we don't require our non-resident alien accounts to have ITINs. My understanding is that a non-resident alien can receive an ITIN or SS# (in some cases). With this new reporting requirement of interest paid to non-resident aliens, will we need ITINs on all of our NRA accounts? Otherwise what number do we report them under on the 1042-S?

Sole Proprietor CTR-Use TIN or SSN#?

11/05/2012

When filing a CTR on a sole proprietorship where the owner has a separate TIN for the business, which do we supply on the CTR- the SSN for the sole proprietor or the TIN?

Joint Account w/Right of Survivorship Liability

10/15/2012

A joint account with right of survivorship that has a deceased primary owner: What are the ramifications of reporting interest earned on a deceased primary owner's SSN when an account has a surviving joint owner? Who is liable for these ramifications - we, the institution, or the surviving owner(s)? When a primary owner dies, we request that the surviving owner(s) close the existing account and re-open a new one in their name, but we don't REQUIRE it. Are we doing something wrong?

Deceased Tax Reporting Owner on Joint (Procedure)

09/24/2012

When you have a joint account and the tax reporting owner passes away, can you just change the SS# on the account to the surviving party and leave the account open or should you close that account and open a new account?

Pages

Most Popular Compliance Content

Handling Reg E "Dated" Claims

12/29/2024

In July, a customer submitted a Reg E dispute for debit card transactions which happened in March, April, and May. The first statement was in April. The customer still has his card. The dispute team processed the claim, eventually finalizing it by crediting the customer for the first statement plus 60 and denying the remainder. Earlier this month (September), the customer filed another claim for the same merchants but for an earlier period, December-February. Do you agree that this must be treated as a separate claim because the first one was already made final? If the second claim came in before the first was closed I am assuming we can combine the two since the same merchants are being disputed.

HMDA Reportable Transaction Exclusions

12/22/2024

I actually referenced these as well which is what I used to support my interpretation; however, the other interpretation I heard the reason they said they got to that was following the citations along with the HMDA reportable transaction exclusions. So 12 CFR § 1002.104(b)(2) then if you go to the citation referenced there 12 CFR 1003.2(e) then go to the 1003.3 (C) referenced there. So looking at those exclusions it doesn’t mention anything in regards to if your bank is in an MSA or not but #11 references FI that have fewer than 25 loans. Hence, that being their reasoning that the only way non HMDA banks would exclude HMDA transactions was if they were non-HMDA due to loan volume. I’m not disagreeing with your answer because that was our interpretation as well but when following the citations that they used to come up with their interpretation and can see why they would maybe think that.”

Pages

Penalties View All

Search Topics

Compliance Topics