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UK/USA bank account?

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Old Aug 16th 2014, 12:25 pm
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Default Re: UK/USA bank account?

We bank with BB&T and love it! We transfer money to our account monthly to pay US bills each month and have never had a problem. Their customer service is excellent and they treat us like VIPs every time we have any interaction with them. They bought out Bank Atlantic in Florida, so have a good presence there. They also have aggressive expansion plans across the USA so are growing.

They also have a good phone app and online banking.
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Old Aug 16th 2014, 5:30 pm
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Default Re: UK/USA bank account?

I was walking by the local Citibank the other day and the man who usually serves me was outside smoking. So I stopped and asked him whether I could open an account for someone who doesn't have a SSN. He said yes, as long as they have a passport and proof of address, no problem.
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Old Aug 17th 2014, 2:30 pm
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Default Re: UK/USA bank account?

Originally Posted by Steve_
The OP sounds like she's in a non-immigrant category and I don't think it's wise to use an on-line bank unless you're a US citizen or LPR. In fact I can't think of any that allow you to sign up on their website unless you are a US citizen or LPR.

The reason why is the USA PATRIOT Act, which amended the Banking Act to require banks to check the ID of aliens in person, essentially. Theoretically once you have an account, they can open other accounts for you online or over the phone but in reality they often want you to show up at a branch.

This is the reason to use a bank that has branches - the reason I recommended TD and BMO Harris is because they have a decent presence in Florida and although it's a massive generalization I find Canadian banks better at dealing with bureaucracy. Also being in Florida they have a lot of Canadians show up who want to open accounts, so they're used to dealing with foreigners.
I'm pretty sure Pulaski is correct, and it's the SSN that's important. I have opened two online banking accounts plus a brokerage account in the last year as the holder of an L1 visa.
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Old Aug 19th 2014, 11:23 pm
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Default Re: UK/USA bank account?

Originally Posted by Owen778
I'm pretty sure Pulaski is correct, and it's the SSN that's important. I have opened two online banking accounts plus a brokerage account in the last year as the holder of an L1 visa.
Nope, SSN has zilch to do with it. I've got one and I'm here to tell you it makes sweet FA difference.

I quoted the regulations, have a read of them. What they're trying to do is stop terrorists from opening bank accounts and plenty of people have an SSN who don't live (and can't live) in the US, prior to 1996 the SSA handed them out pretty freely.

Hence the "Customer Identification Program" that banks must have and that's where it gets silly. Because the CIP regs are a bit vague.

Good on you if you've managed to do it, but I know one person personally who had L-1 and they were only able to get an on-line account because they happened to live near the office block where said on-line bank had it's HQ and could go in personally to show them their ID.
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Old Aug 19th 2014, 11:24 pm
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Default Re: UK/USA bank account?

Originally Posted by Bob
They don't need to be. They have a book that has all the passports/drivers licenses/currency from around the world, with their security features. It's massive and weighs a ton, but all they have to do is flick through to the country and then compare.

It's updated quarterly.
Actually it's on the web now. But you have to subscribe to it.
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Old Aug 20th 2014, 2:03 am
  #51  
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Default Re: UK/USA bank account?

Originally Posted by Steve_
Nope, SSN has zilch to do with it. I've got one and I'm here to tell you it makes sweet FA difference.
Thank you for telling me.

These are the instructions from GE Capital Bank, who I opened an account with last year:
Please have the following information on hand to set up your new Account(s):
Social Security Number
Date of birth
Valid U.S. physical address
Email
Phone number

Note: Account Owners must be at least 18 years old and must be a U.S. citizen or legal resident.

IMPORTANT INFORMATION ABOUT OPENING A NEW ACCOUNT:

To help the government fight the funding of terrorism and money-laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. This means that when you apply for an account, we will ask for your name, address, date of birth, Social Security Number and other information that will allow us to identify you.
Ally Bank state:
Each account owner must:

Have and provide a Social Security number
Have a US mailing address
Be at least 18 years old
Schwab say:
Open an account online in about 10 minutes

Before you start, be sure to have this information with you for each applicant:

U.S. permanent resident address
Social Security number or Tax ID
Driver's license number, state, and expiration date
Employer's name and mailing address (if you have an employer)
If you want to finish the application later, you can always save and return.

If you are not a U.S. resident, visit our Global site or download our Schwab One International Application.
They all require SSN, but it's not yet clear to me why. I'm now going to do a bit more investigation.
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Old Aug 20th 2014, 2:24 am
  #52  
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Default Re: UK/USA bank account?

So a few more details:

31 CFR 103.121 - Customer Identification Programs for banks, savings associations, credit unions, and certain non-Federally regulated banks.

In this regulation, "US person" means:
(i) A United States citizen; or
(ii) A person other than an individual (such as a corporation, partnership, or trust), that is established or organized under the laws of a State or the United States.
In this regulation, an individual "US person" has to be a citizen. Not that it matters, though, as the only difference is that US persons must specifically have a taxpayer identification number. US persons can use that or alternatives.

This is the required minimum for identification:
(1) Name;
(2) Date of birth, for an individual;
(3) Address, which shall be:
(i) For an individual, a residential or business street address;
(ii) For an individual who does not have a residential or business street address, an Army Post Office (APO) or Fleet Post Office (FPO) box number, or the residential or business street address of next of kin or of another contact individual; or
(iii) For a person other than an individual (such as a corporation, partnership, or trust), a principal place of business, local office, or other physical location; and
(4) Identification number, which shall be:
(i) For a U.S. person, a taxpayer identification number; or
(ii) For a non-U.S. person, one or more of the following: a taxpayer identification number; passport number and country of issuance; alien identification card number; or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard.
This must then be verified:
(ii) Customer verification. The CIP must contain procedures for verifying the identity of the customer, using information obtained in accordance with paragraph (b)(2)(i) of this section, within a reasonable time after the account is opened. The procedures must describe when the bank will use documents, non-documentary methods, or a combination of both methods as described in this paragraph (b)(2)(ii).
(A) Verification through documents. For a bank relying on documents, the CIP must contain procedures that set forth the documents that the bank will use. These documents may include:
(1) For an individual, unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver's license or passport; and
(2) For a person other than an individual (such as a corporation, partnership, or trust), documents showing the existence of the entity, such as certified articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument.
(B) Verification through non-documentary methods. For a bank relying on non-documentary methods, the CIP must contain procedures that describe the non-documentary methods the bank will use.
(1) These methods may include contacting a customer; independently verifying the customer's identity through the comparison of information provided by the customer with information obtained from a consumer reporting agency, public database, or other source; checking references with other financial institutions; and obtaining a financial statement.
(2) The bank's non-documentary procedures must address situations where an individual is unable to present an unexpired government-issued identification document that bears a photograph or similar safeguard; the bank is not familiar with the documents presented; the account is opened without obtaining documents; the customer opens the account without appearing in person at the bank; and where the bank is otherwise presented with circumstances that increase the risk that the bank will be unable to verify the true identity of a customer through documents.
(C) Additional verification for certain customers. The CIP must address situations where, based on the bank's 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 account, 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 the verification methods described in paragraphs (b)(2)(ii)(A) and (B) of this section.
As you can see, there are multiple ways for banks to verify identity. Turning up at a branch is only one way, despite your earlier statement. The online banks use method (B)(1) above - you'd have to check their individual policies, but I imagine they verify SSN against information from "a consumer reporting agency" (i.e. a credit rating agency) and then phone the customer.

Possibly you or someone you know didn't have a credit rating in the US? That's the only way I can see you'd have a problem. I have seen no bank that requires you to be a citizen or LPR.
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Old Aug 20th 2014, 2:25 am
  #53  
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Default Re: UK/USA bank account?

Originally Posted by Owen778


They all require SSN, but it's not yet clear to me why. I'm now going to do a bit more investigation.
Maybe more to do with end of year tax forms, rather than ID verification?
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Old Aug 20th 2014, 2:30 pm
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Default Re: UK/USA bank account?

Originally Posted by Steve_
Nope, SSN has zilch to do with it. I've got one and I'm here to tell you it makes sweet FA difference.

I quoted the regulations, have a read of them. What they're trying to do is stop terrorists from opening bank accounts .....
That is incorrect. If you have read the regulations you have either misinterpreted them or misunderstood them.

The purpose of CIP is for the bank to to prove that it knows who its customer is, nothing more, nothing less. ..... From that, they can then search for the name of a terrorist or drug dealer when requested to do so, confident that their customer records are accurate, but the purpose of CIP is not to "stop terrorists from opening bank accounts".

Last edited by Pulaski; Aug 20th 2014 at 2:41 pm.
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Old Aug 20th 2014, 2:33 pm
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Default Re: UK/USA bank account?

Originally Posted by Owen778
So a few more details:

31 CFR 103.121 - Customer Identification Programs for banks, savings associations, credit unions, and certain non-Federally regulated banks.

In this regulation, "US person" means:

In this regulation, an individual "US person" has to be a citizen. Not that it matters, though, as the only difference is that US persons must specifically have a taxpayer identification number. US persons can use that or alternatives.

This is the required minimum for identification:


This must then be verified:


As you can see, there are multiple ways for banks to verify identity. Turning up at a branch is only one way, despite your earlier statement. The online banks use method (B)(1) above - you'd have to check their individual policies, but I imagine they verify SSN against information from "a consumer reporting agency" (i.e. a credit rating agency) and then phone the customer.

Possibly you or someone you know didn't have a credit rating in the US? That's the only way I can see you'd have a problem. I have seen no bank that requires you to be a citizen or LPR.
Owen might not be a self-proclaimed know-it-all, but he has a better grasp of CIP than a certain somebody!

The question of citizenship is a bit of a stumbling block because there is no flag for that, and no way for a bank to be able to tell whether any one person is a citizens or not, other than ask for a birth certificate (which might just confuse matters if they were born outside the US to a US citizen parent, or naturalized) a passport, (which many citizens don't have), or a certificate of naturalization (which only naturalized citizens have). In short coming to a certain conclusion as to whether someone is a US citizen is a lot harder in practice than most people would imagine to be the case.

Last edited by Pulaski; Aug 20th 2014 at 2:40 pm.
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Old Aug 20th 2014, 3:26 pm
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Default Re: UK/USA bank account?

Originally Posted by Pulaski
Owen might not be a self-proclaimed know-it-all, but he has a better grasp of CIP than a certain somebody!

The question of citizenship is a bit of a stumbling block because there is no flag for that, and no way for a bank to be able to tell whether any one person is a citizens or not, other than ask for a birth certificate (which might just confuse matters if they were born outside the US to a US citizen parent, or naturalized) a passport, (which many citizens don't have), or a certificate of naturalization (which only naturalized citizens have). In short coming to a certain conclusion as to whether someone is a US citizen is a lot harder in practice than most people would imagine to be the case.
Thanks.

There is no requirement in the CIP to distinguish between a US person and a non-US person, just that US persons must provide their taxpayer identification number. The SSN is acceptable ID for everyone, though. So, if the online bank demands everyone provide their SSN, they don't have to distinguish between US and non-US persons. Non-US persons without an SSN can either contact the bank for assistance with other forms of ID, or the bank can ignore them.

I wonder if any of the online banks actually publish their CIP policy?
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Old Aug 21st 2014, 9:21 pm
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Default Re: UK/USA bank account?

Originally Posted by Owen778
As you can see, there are multiple ways for banks to verify identity. Turning up at a branch is only one way, despite your earlier statement. The online banks use method (B)(1) above - you'd have to check their individual policies, but I imagine they verify SSN against information from "a consumer reporting agency" (i.e. a credit rating agency) and then phone the customer.
As I said the regs are vague and they tend to interpret them conservatively. This is not my imagination, I've had the problem for years and years. I've actually had an argument with one bank lawyer over what they mean. For example:

The bank's non-documentary procedures must address situations where an individual is unable to present an unexpired government-issued identification document that bears a photograph or similar safeguard; the bank is not familiar with the documents presented; the account is opened without obtaining documents; the customer opens the account without appearing in person at the bank; and where the bank is otherwise presented with circumstances that increase the risk that the bank will be unable to verify the true identity of a customer through documents.
Must address. How do you do that? By using documentary methods. Those words render the section almost meaningless. And as soon as you go to documentary methods, they want to see the documents:

For an individual, unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, such as a driver’s license or passport;
Well a DL doesn't evidence nationality (although a US one usually is evidence of legal residence because of DHS SAVE - but not a foreign one). So then you're in the realms of a passport. So then you have this situation where a lot of CIPs require you to show up in person if you have a foreign passport because they just don't trust it and want to see that you match the picture, to prevent fraud. So if you have an LPR card, they will trust that (because it's issued by the USG).

They have to have your SSN for the W-9 (if you have one). The point I was making was, it makes no odds for the purposes of whether they will open an account for you or not. Or it might, but it's not necessarily to do with the CIP.

Last edited by Steve_; Aug 21st 2014 at 9:44 pm.
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Old Aug 21st 2014, 9:37 pm
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Default Re: UK/USA bank account?

Please have the following information on hand to set up your new Account(s):
Social Security Number
Date of birth
Valid U.S. physical address
Email
Phone number

Note: Account Owners must be at least 18 years old and must be a U.S. citizen or legal resident.

IMPORTANT INFORMATION ABOUT OPENING A NEW ACCOUNT:

To help the government fight the funding of terrorism and money-laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. This means that when you apply for an account, we will ask for your name, address, date of birth, Social Security Number and other information that will allow us to identify you.
Which rules me out obviously. US citizen or legal resident. And what do they mean by "legal resident"? And you can't use a physical US address on a W-8BEN otherwise you start getting nasty letters from the IRS.

Ally Bank state:

Each account owner must:

Have and provide a Social Security number
Have a US mailing address
Be at least 18 years old
Once again, rules out foreigners who live abroad, and I wonder what it actually says when you get to the sign-up page.

Schwab say:
Quote:
Open an account online in about 10 minutes

Before you start, be sure to have this information with you for each applicant:

U.S. permanent resident address
Social Security number or Tax ID
Driver's license number, state, and expiration date
Employer's name and mailing address (if you have an employer)
If you want to finish the application later, you can always save and return.

If you are not a U.S. resident, visit our Global site or download our Schwab One International Application.
The last line means basically, we'll open an account for you at one of our overseas branches if we've got one there. "Permanent resident" address. What does that mean?

Mmm anyway to just double-check this ten years plus of stress I've had is not my imagination, I went to the most obvious on-line bank I could think of, Bank of Internet and when you get to the sign-up page (not the general details you've quoted) there is a drop-down box for "citizenship" that has only two options: US citizen or resident alien and then at the bottom it asks the question:

Under penalties of perjury, I certify that the above Social Security/Taxpayer ID number is correct, I am not subject to backup withholding due to failure to report interest and dividend income, and I am a U.S. person.
A US person being usually a US citizen or LPR... but in the regulations it says:

(7) U.S. person means:
(i) A United States citizen; or (ii) A person other than an individual (such as a corporation, partnership, or trust), that is established or organized under the laws of a State or the United States.
So that doesn't even appear to include an LPR!

Now theoretically they could come up with a CIP that allows non-US persons to open accounts on-line... but they haven't. And that has been my wide experience with various banks.
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Old Aug 21st 2014, 9:57 pm
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Default Re: UK/USA bank account?

Well I just went to Ally.com and got this:

Opening Accounts from Outside the US

For security reasons we only accept new applications from within the US. To open an account, please call 757-247-2559.
So after defeating their IP restrictions, it says:

IMPORTANT INFORMATION ABOUT OPENING A NEW ACCOUNT

To help the United States Government fight terrorism and money laundering, Federal law requires us to obtain, verify, and record information that identifies each person that opens an account.

What this means for you: when you open an account, we will ask for your name, a street address, date of birth, and an identification number, such as a Social Security number. We may also ask to see your driver's license or other identifying documents that will allow us to identify you. We appreciate your cooperation.
Which seems to be referring to the CIP and that they want you to be a US person... because obviously your DL will have to be American if the residence address has to be in the US. Not sure if they'll open an account for a person in a non-immigrant status, I'd have to go through the whole sign-up to find out.
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Old Aug 21st 2014, 10:26 pm
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Default Re: UK/USA bank account?

I'm not going to address all of your points in detail, since on one that is central to your argument, you are confused.

Originally Posted by Steve_
Must address. How do you do that? By using documentary methods. Those words render the section almost meaningless. And as soon as you go to documentary methods, they want to see the documents:
For people with SSNs, they can address it through the credit bureaus or other databases. This is specifically allowed by the regulation, as I explained.

A US person being usually a US citizen or LPR.
No! A US person is specifically defined in each relevant regulation. For tax reasons, a US person is any US citizen or resident. This includes both permanent residents, and temporary residents who satisfy the substantial presence test. If you were ever a US resident taxpayer, you could have opened a US online account, if only you'd realised that this made you a US person.

Classification of Taxpayers for U.S. Tax Purposes
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