Topic: Customer Identification Program (CIP)
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Can a safe deposit box be leased by a trust? Can a safe deposit box be leased by a business?
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We are not aware of any law that prohibits trusts or business entities from leasing a safe deposit box. However, we note that safe deposit boxes are subject to Customer Identification Program (CIP) regulations, which require you to collect (at a minimum) the name, address and social security or other tax identification number of every…
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For purposes of reporting interest to the IRS, should we use the social security number found on an ID card stating “Valid for work only with DHS authorization”?
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Yes, a social security card stating “valid for work only with DHS authorization” is a valid type of social security card. The IRS suggests that you obtain taxpayer identification numbers from your customers using either a Form W-9 for resident aliens or a Form W-8 for other foreign persons. For resources related to our guidance,…
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Can you provide me with the exact verbiage that permits a financial institution to conduct on-site visits for its customers?
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The FFIEC's most recent BSA/AML Examination Manual states that customer due diligence information can be confirmed through banking references, correspondence, telephone conversations with the customer, and “visits to the customer's place of business.” Also, the manual specifically suggests conducting on-site visits for certain customers, such as third-party payment processors, cash-intensive businesses and money services businesses,…
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Do we need to update account information under the Customer Identification Program (CIP) rules for a trust that has held an account with our institution since 1987? The account lists two signers but no trustees.
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No, the CIP rules do not require you to update the account information for this account, but it may be prudent to obtain additional information to confirm the accountholder’s “true identity,” which in this case would include obtaining information about the trustees for the trust. The CIP rules permit banks to grandfather certain accounts opened…
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Do we need an individual’s social security number to open an account? An individual from Mexico wants to open an account with his taxpayer identification number.
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No, you are not required to obtain a social security number to open an account for a non-U.S. person. In lieu of a social security number for a non-U.S. person, the Customer Identification Program (CIP) rules require you to obtain one or more of the following: a taxpayer identification number, passport number and country of…