CIP regulations require you to obtain the individual's SSN and other ID information if the club doesn't have its own legal existence under the laws of your state. But if the account will earn interest, IRS regulations require that you get an EIN for the owner of the account, whether or not it has a separate legal existence.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8