08/16/2010
I work in the BSA Department. My bank was just acquired by another bank and we found a customer of theirs who runs a factoring company under his personal TIN. His activity consists of depositing checks payable to other businesses (in the week period I have access to - databases not merged yet - the checks range from $25 to $12,500) and withdrawing cash (about $250,000/month) to pay his clients. From what I can tell, based on online research, the debtor businesses should be remitting payment directly to the factor, not the original vendor, and the factor should not be dealing in cash in any way. It appears that he may be acting as an unregistered check casher for businesses. How can I determine if this is the case? Do you agree that he should not be depositing third party business checks?
08/09/2010
We have a customer who runs an insurance agency titled under his name,(John Doe, Agent). If he wants to open an account so that the premiums he collects on behalf of certain companies can be swept out by ACH on a regular basis, how should it be set up? He is a sole proprietor; should he have access to the funds, TIN or SSN for the account? He wants "trust account" in the title. What if he receives an IRS levy, could these funds be taken? Please let me know the appropriate way to set up this account type.
08/02/2010
Can a joint owner of a personal account assign/give an account title modifier/nickname to the account that would include "association" in the title (i.e. "nowhere county professional association")? This is a personal account under an individual social security number. The customers are not buying, selling, or operating in a business manner. This is in essence a club.
07/12/2010
Recently in dealing with a non-resident alien, an ITIN was presented at the time of account opening. After researching on the irs.gov website and calling the IRS, I was told that an ITIN can only be used to file a US tax return. It is not to be used for any other purpose, including opening a bank account. In your question and answer page about non-resident aliens it mentions and ITIN can be used . Please clarify.
04/05/2010
I am reviewing a trust where two individuals are the trustees of a Revocable Trust for their mother. The two individuals, trustees, want to add their mother and a sister as agents. The trust agreement allows for the appointment of agents. They want thier mother's social security check to go into this account that is using a #38 TIN that is not the mother's social security number. Will there be a problem with a direct deposit of social security going into a trust account where the TIN on the account is not the social security number of the person receiving the social security benefit?
03/29/2010
For purposes of setting up an estate account, who is considered the customer for purposes of CIP?
03/15/2010
When granting access to a safe deposit box, bank policy requires use of a private coupon room, but many customers want to access their boxes quickly, in the vault itself. Is there an industry best practice, either for or against, granting access to a safe deposit box while inside the vault?
03/01/2010
We have a sole proprietorship account opened with the customer’s social security number. The customer wants to change it to an LLC account, do we need to required them to provide a TIN or EIN?
02/08/2010
When completing a CTR for a deposit made into an account that reads "The Doe Family Trust," what is the proper way to complete Section A of the CTR? The Memorandum of Trust Agreement states John and Jane Doe are the settlors and trustees for this trust. John Doe's SSN is being used as the identification number for this trust.
11/23/2009
We had a CTR returned to us for a name/TIN mismatch. The CTR was filed on a charitable organization. We have conflicting information in our records pertaining to the TIN. We have not been able to get in contact with the individual who opened the account or the charitable organization itself. Time is running out on getting the correction back to the IRS. What are our options?