Academic journal article ABA Banking Journal

Handling Customer ID When Banking the Amish

Academic journal article ABA Banking Journal

Handling Customer ID When Banking the Amish

Article excerpt

Q. Our bank is taking steps to update all account records and we want to ensure compliance with the Customer Identification Program (CIP) rule under the USA Patriot Act. Our bank has several open accounts where we have no Social Security Number (SSN). Many of these accounts are held by Amish customers. Management wants to mail letters requesting that a SSN be provided for the account holders, and if not provided within a set period of time, we would close the account. Are we violating any laws by making this request? How should we explain this request to these customers if they ask why we are requiring the SSN?

A. No, you are not violating any laws. But you do raise some interesting questions.

The first question is whether or not these are "grandfathered" accounts; accounts established prior to Oct. 1, 2003 are exempt from CIP as long as your bank has a reasonable belief that you know the true identity of these customers.

The next question you must ask is whether you must have a Social Security Number for all accounts. The rule only requires the bank to have an "identification number." For most U.S. citizens who are individuals, that number will be their Taxpayer Identification Number (TIN) which is most often, but not always, an SSN. …

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