Knowing your customer

[Trotter, Frank]

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On Thursday, December 07, 2000 10:09 AM
The Following Was Transmitted:
<snip>
> My original point, possibly taken too
> literally at the outset here, is that in
> most jurisdictions it is more or less
> impossible to get a US bank account without
> a social security number, <snip>

It is in fact required of US entities.

> I am not, of course, a banking lawyer, but
> I certainly hang out with enough of those
> folks these days, I've certainly had enough
> of this stuff shoved into my head over the years,
> and, I expect that to get a bank account
> without a Social Security number in most states
> of the US, you probably need to prove that you
> are indeed a foreign national, *and* provide a
> valid passport as proof of same, and that,
> frankly, the passport number would be used
> *somewhere* as a proxy for SSN where possible.

There are two issues here.

If you are a non-resident alien (an "NRA" - I've always loved that
term) you can sign a W-8 stating that you are an NRA and that you are
not required to have a TIN or SSN.  That takes care of you from that
angle and by definition you don't need a number.

The more difficult element is the "know your customer" rule where
such a signing doesn't really prove anything.  At the end of the day,
the bank - and more specifically an individual banker is personally
liable (the "banker goes to jail" principal) - is required both to
assert that they know the customer and in the event of untoward
activity, which is rather broadly defined, report such activity to
the authorities if it is discovered or !!! should have been
discovered !!! - This latter principal IMO is the one that creates
the extreme level of conservative behavior in the US.

<snip>

Personal comments only.
=====================
Frank O. Trotter, III
President - everbank.com

Spank your banker and come on over to
http://www.everbank.com

everbank is a Division of Wilmington
Savings Fund Society, FSB

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