10/18/2004
How do we complete Part 1 of the CTR for a sole proprietor's deposit of money if they are not conducting the transaction? We know Section B would be who is conducting the transaction. Do we have to fill out 2 Section A's, one for the business information, and one for the sole proprietor's personal information?
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.
11/03/2003
What is our right to offset a delinquent personal loan with a DBA deposit account bearing the same social security number?
04/07/2003
I have a customer who has an LLC set up with one owner. They would like to use their own social security number. Would I set this up any differently? Do I use his name or the name of the LLC first on our computer system? I was concerned with the interest reporting.
07/01/2002
05/01/2002
(Editor's Note: Legislation has again been introduced to change the limits of FDIC Deposit Insurance which, if passed, will initiate many questions from our depositors.
04/01/2002
When one tax ID number is used for multiple accounts, each with different DBA names, and the combination of deposits made in one day exceeds the CTR threshhold, are you required to list each DBA as a benefactor?
03/04/2002
Borrower is a corporation with one shareholder. All business assets are pledged as collateral. Lender wants the spouse to also sign on loan docs, with the concern being that she may gain ownership of at least 1/2 assets should they divorce. Would asking her to sign be a violation of Reg B? If so, does the lender have a bona fide concern regarding assets or does the fact that the borrower is a coporation make this a non-issue? Flip side: What about if the borrower was a partnership or sole proprietorship and the spouse has no role in the affairs or function of the business? (e.g., farmer Bob who takes a loan secured by crops.) Lender wants to add wife to loan as a condition for the same reasons listed above. How should I advise my lender?
02/11/2002
When making a loan to a sole proprietorship can you list the 'DBA' under the individuals name and SSN?
01/14/2002
Funds Transfer: Developing Commercially Reasonable Security Procedures For Your Bank, Part 2
by Dana Turner