How to create a verified customer for a joint tenancy

API Support Customers
1

The docs don’t discuss how to create a verified customer for a joint tenancy. This could be a Tenancy in Common, Tenancy by the Entirety, or Joint Tenancy with Rights of Survivorship.

This is somewhat similar to a trust, which can have multiple trustees. The docs tell us to us treat a trust as a sole proprietorship, where the owner is the trustee that performs registration.

Should we do the same for joint tenancy?

2

Hoped for an answer by now. I’m going ahead and creating the verified customer as a sole proprietorship, as directed for an unincorporated association or trust.

Please let me know if that is incorrect.

3

Hi @gfb107 – we do not have an account type for joint tenancy specifically. What kind of funding source is being attached to the customer, is it a personal consumer account or is it a business account? This will help us determine which existing account type you can use.

4

This is a general question about the API, not a question about a specific customer.

Typically, a joint tenancy is a business relationship, and will have multiple owners, but is not required to have an EIN.

A joint tenancy might also be spouses using a joint personal account.

5

Thanks for the clarification, Greg. Our Compliance team recommends the following for Joint Tenancy customer.

The authorized account holder should be what dictates the type of account. If it is a business account then it should be set up under a business account. Soleprop account types are really meant for one owner, but yes we also allow a soleprop to be used for trusts because our product is not created for every scenario.

If the funding source is not in a business name, and say there are several individuals as authorized signers, they may just want to set up as a personal VCR under one of the authorized signer’s names, but if it is a business account it really needs to be under a business account type to ensure the correct SEC code is applied since business accounts have a shorter return window.

6

I think the only business type the API supports without a controller and ein is a sole proprietorship.

So even though sole proprietorship is not a true match for joint tenancy (which is also the case for a trust or unincorporated association), it is the only choice that works with the Dwolla API.

Have I missed something?

7

Hi Greg,

That is correct! Except, if the bank account to be used by the joint tenancy is a personal consumer bank account, then they must be created as a Personal Verified Customer to ensure that there are no issues when creating transfers.

8

Thanks