Certified Regulatory Compliance Manager (CRCM) Practice Exam

The requirement for a bank to obtain the Taxpayer Identification Number (TIN) from a deposit account holder is rooted in compliance with the Bank Secrecy Act (BSA) and Regulation Q. If the bank does not have a TIN at the time of account opening, it is mandated to obtain this information within a reasonable time. This requirement is crucial for the bank to fulfill its obligations regarding tax reporting and to ensure that the institution is not facilitating tax evasion. The emphasis on obtaining the TIN within a reasonable timeframe is also tied to the necessity for accurate reporting to the Internal Revenue Service (IRS) as part of the tax compliance process. If the bank fails to secure the TIN, it could face potential penalties or issues related to compliance with regulations concerning tax obligations. In contrast to the other options, which suggest actions like withholding interest or closing the account, these measures are not specified as immediate requirements under the BSA when a TIN is not initially provided. Instead, the act of securing the TIN ensures that the account holder's information is accurate and complete for regulatory compliance.