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BSA Record Retention-Certificate of Deposit

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Question: 
In regards to BSA record retention requirements, if a business has a certificate of deposit and an individual who is authorized to sign for that business presents that certificate, are we to keep record of the business (the customer) name, address, and TIN or the name, address, and TIN of the authorized individual?
Answer: 

An authorized signer is not your customer. Plus, almost all CDs are all book entry and there is no "certificate" unless you are issuing negotiable CDs.

First published on 10/15/2017

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