01/09/2006
Working in a coastal area where the sale of property is abounding, we have several clients who escrow funds, particularly, for 1031 exchanges. Those monies may be placed in an escrow account and held for a period of time (145 days). The account is usually opened by an attorney or title company with the signors/agents being authorized representatives of the respective firm. The principals, of course, are the individuals for whom the funds are being held and may live anywhere within the United States. Are we correct in assuming our customer is the agent and/or firm who deposits and withdraws the proceeds from the account; and as such, the agent is responsible for securing identity of the individual from whom they collect and disburse? (Please keep in mind the principal in whose behalf the funds are deposited may benefit from interest paid on the account.)
11/07/2005
ABA Money Laundering Enforcement Conference -- Days 2 & 3
by Ken Golliher
Principal, Pegasus Educational Services, LLC
10/17/2005
When does the bank need to require an individual taxpayer identification number (ITIN) and when would it require the social security number of foreign persons opening an account? Could a foreign person open an account with just a current passport and a completed W-8 BEN for a non interest bearing account?
06/01/2005
Question: We had our first Native American open an account and tell us that they do not have a tax ID number because they are exempt.
05/23/2005
What is your opinion regarding placing the tax id/ssn on the front of a note next to the borrowers name? For example: smith (999 99 9999)
05/16/2005
What is considered sufficient information/documentation for customer identification for a revocable trust?
05/02/2005
My question is we have a business with two separate accounts but using the same TIN. Are we required to file two designation of exempt forms in this instance? Our recent FDIC exam said yes and not that I'm doubting them I wanted to find out for sure. If we report the same business name twice with the same TIN it seems like one form would wash out the other form.
05/02/2005
If you have a business exempt as a Phase I and they are currently going through a reorganization, should you remove them as a Phase I Exemption?
05/02/2005
BSA Exemption: The bank has elected to exempt its eligible customers by TIN. If a customer opens a new account with the same TIN, is that account automatically exempt or does the account have to be open for a specified time before it is to be included with the other accounts under the same TIN?
05/01/2005
Question: We have a customer who refuses to provide us with a TIN for his account. He says that he doesn't have one and refuses to get one. He's very anti-government.