Forum Discussion
westernrvparkow
Mar 02, 2016Explorer
blangen wrote:And when the Feds fine Fidelity another $1,000,000 dollars for failing to follow the identification laws they can say "The guy told us on the phone his domicile was in Texas today, Florida tomorrow and Syria next Thursday" and be totally off the hook. I can assure you of one thing, if my business ever got a million dollar fine for failing to follow the letter of some law, I would follow the letters of that law all the way past the final "Z".path1 wrote:
Not there fault, read pdf file below. If they don't follow manual they are out of business. We've had no problem with fidelity. Pull out the parts that apply to you and talk with somebody that knows something. And those people are not usually not in local office.
https://www.ffiec.gov/bsa_aml_infobase/documents/BSA_AML_Man_2014_v2.pdf
Thanks for the above .pdf. Interesting read. It appears the crux of the matter is the definition of "residence" and, while some other legal definition sources get quite involved based on state, most resolve down to the following:
"residence - Legal Definition. n. A place of abode with some permanence; residence requires bodily presence and is distinct from domicile, which requires both bodily presence and intent to make it one's home." (I added the emphasis)
To my understanding, so long as one has their domicile defined appropriately (all the i dotted and t crossed in a full-timer friendly State like South Dakota, for example), "residence" address shouldn't be an issue for any institution.
One more interesting point in the above linked .pdf... It says institutions must define their own procedures for knowing who their customers are. It doesn't really spell out exact requirements. It also says that institutions can utilize documentation, third party info (like other banks, credit reports, etc) as well as social inquiries. In short: simply calling up any institution you're having troubles with and explaining your full-timing, where you currently are, where you're going next week... may be all they need to see some continuity and feel comfortable that you are real. Problem solved.
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