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Automatically Exempting Customers w/ the Same TIN

Answered by: 
John Burnett
Randy Carey

Question: 
BSA Exemption: The bank has elected to exempt its eligible customers by TIN. If a customer opens a new account with the same TIN, is that account automatically exempt or does the account have to be open for a specified time before it is to be included with the other accounts under the same TIN?
Answer: 

Answer by John Burnett: Banks designate exempt persons, not accounts. Assuming that the new account is "exemptible," the account falls under the customer's exemption on "Day 1."

An "exemptible" account is one that is a transaction account or MMDA. That would include any savings account that permits third party payments.

Answer: 

Answer by Randy Carey: John is correct, but I would also suggest that you may need to analyze why a new account has been opened and are they transacting exemptable business through it. Anytime an account relationship changes like this is a great time to do a little re-examination of the customer.

First published on BankersOnline.com 5/2/05

First published on 05/02/2005

Filed under: 
Security
Filed under security as: 
IT
TIN

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