01/30/2006
My holding company is getting ready to merge our three banks. Do we need to refile the current exempt persons from CTR reporting under our new EIN and routing numbers? Can this be handled at time of review?
01/09/2006
A customer made an $8,500 cash deposit to his personal account. On the same day a deposit was made into a partnership account, in which the person is a partner, of $3,000. That deposit was made by another partner. Our customer says that although his SSN is used on the partnership account, the money put in by the other partner is that partner's money, not his and therefore we should not file a CTR. Do we file a CTR?
07/04/2005
We have a business exempt from CTR reporting. The business owners have recently purchased another business that is held as a separate entity with a different EIN. The same person (one of the owners) deposits cash exceeding $10,000 into both accounts on the same day. Do I wait for one year to exempt the second business? If so, how do I report the cash transactions until that year is up? Remember, one business is exempt, the other is not but the same person deposits the cash. Or is it permissible to exempt the second business based on the established relationship with the business owner?
02/07/2005
The bank has a customer with two separate business accounts. One is a sole proprietorship mini-mart; the other is a corporation with a separate EIN. He frequently deposits money into these accounts, which when aggregated together totals over $10,000. However, when treated separately, they do not total over $10K. His business accounts are exempt. Should he remain an exempt customer when he rarely deposits over $10K in each account? Should we file a CTR on him (personally) for the cash transactions over $10K, even though they are for his business?
10/18/2004
If a sole proprietorship account is styled Jane Doe dba Jane's Jeans, we would use Jane Doe's SSN for the tax ID. If Jane's Jeans has its own EIN, should the account be styled the same? I always understood the first name on the legal title should match the tax ID number.
02/23/2004
When opening a Limited Liability Corporation can you use the individual's social security number, or should the customer obtain a federal tax ID number?
09/08/2003
Prior to the CIP being enforced beginning October 1, is it a current rule within the Patriot Act or other law or regulation that we must obtain social security numbers for authorized signers on a business account? What about after October 1?
09/02/2003
We have two customers who want their safe deposit box put in the names of both of their trusts. They want the box styled His Trust Name @ 50% and also Her Trust Name @ 50%. Can this be done? The attorney they use has also sent another request for another customer to do the same thing with their safe deposit box. I don't see how one box can be put in the name of two trusts. If this is possible, what social security number or TIN do we use?
06/02/2003
When opening an account for a new customer must the individual present his or her social security card or provide documentation to verify the SS#, as a result of the provisions of the USA PATRIOT Act? Is not providing the SS# along with proper ID enough? Many individuals don't have anything with the SS# on it or carry it with them. We don't want to turn prospective account holders away for not having their SS Card.
05/05/2003
It has always been my understanding that when an account is opened for any "entity" (non-person) it is necessary to require an EIN, as opposed to accepting one of the signer's social security number. Is that correct and, if not, where in the regs could I find guidance on this subject?