Non-Resident Signer With No SSN

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Question:

New joint signer lives in China and does not have a social security number. The primary signer lives in Washington and has a SSN. Bank Secrecy Act states each signer must have an ID number on file. Would we have them complete W-8 BEN to add her to the account?

Answer:

The BSA regs don't exactly say you must get a TIN from each signer. From 31CFR103.34(a)(1) "... where the account or certificate is in the names of two or more persons, the bank shall secure the taxpayer identification number of a person having a financial interest in the certificate or account."

Since you have a U.S. Person on the account, you put his name first in the account title, obtain a certified TIN from him and do information reporting on that name/TIN combination. You are not required to obtain identification from the NRA, but in the current environment that would be an exceptionally poor choice. As the account is set up for information reporting on an SSN, the W8-BEN would serve no purpose.

The new final CIP regulations will require you to obtain an identifying number for each customer, however, once they go into effect.

First published on BankersOnline.com 05/19/03