CIP FAQs – When the bank’s customer is a trust, what taxpayer identification number should the bank obtain?

Compliance > BSA > FinCEN FAQs - CIP
Q:  The CIP rule requires a bank to obtain a taxpayer identification number from the customer prior to opening an account from a customer that is a U.S. person.  When the bank’s customer is a trust, what taxpayer identification number should the bank obtain?
 
A:  The taxpayer identification number for a trust is the trust’s employer identification number (EIN).   If the trust is not required to have an EIN under the tax laws, then the bank may obtain the grantor’s taxpayer identification number, consistent with section 6109 of the Internal Revenue Code and the regulations thereunder.  (April 2005)
 

ADDITIONAL INFORMATION
This FAQ was excerpted from the Interagency Interpretive Guidance on CIP Requirements that can be found at the following link:  https://www.fincen.gov/sites/default/files/guidance/faqsfinalciprule.pdf
 

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