Academic journal article ABA Banking Journal

New Signer Won't Disclose SSN

Academic journal article ABA Banking Journal

New Signer Won't Disclose SSN

Article excerpt

Q. We recently established a business account relationship with an LLC (limited liability company), and the LLC provided documentation supporting the entity and identifying the authorized signers on the account.

The LLC recently changed one of the authorized signers, and this individual does not believe he should have to provide us with his social security number. While the business is the customer, the individuals who sign on the account have always provided us identification. Are we over-requesting information, or is there another area I can refer to within the customer information program to help explain why we need to have the signer's SSN on a commercial account?

A. Here's a key paragraph from the Federal Financial Institutions Examination Council BSA/AML manual (http://tinyurl.com/bsaamlmanual):

"The CIP must address situations where, based on its risk assessment of a new account opened by a customer that is not an individual, the bank will obtain information about individuals with authority or control over such accounts, including signatories, in order to verify the customer's identity. This verification method applies only when the bank cannot verify the customer's true identity using documentary or non-documentary methods. For example, a bank may need to obtain information about and verify the identity of a sole proprietor or the principals in a partnership when the bank cannot otherwise satisfactorily identify the sole proprietorship or the partnership. …

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