Consumer complaint received 2018-09-22
Company: CITIBANK, N.A.
State: CA
Product: Checking or savings account
Sub-product: Savings account
Issue: Managing an account
Sub-issue: Deposits and withdrawals

Complaint:
On XX/XX/XXXX, I opened an Interest Checking Account with {$150.00} and Money Market Plus Account with {$60000.00}, in the name of my revocable living trust, at Citibank, N.A., XXXX XXXX XXXX XXXX, XXXX, California XXXX, ( XXXX ) XXXX. XXXX XXXX was my personal banker. 

On XX/XX/XXXX, XXXX delivered a letter to me from Citibank, N.A.,  dated XX/XX/XXXX, requesting that I please contact them as soon as possible ; " Important account information is needed by XX/XX/XXXX. A recent review of your account found that some important information is either missing or out of date. It's critical that you contact us to verify and update your information as soon as possible. Please be aware that because this information is required, if we don't receive the needed information from you by XX/XX/XXXX your account may be blocked to prevent transactions. As a valued customer, we look forward to working with you to resolve this urgent request so as to prevent any adverse impacts to your account. '' On XX/XX/XXXX, I called ( XXXX ) XXXX and spoke with XXXX, who requested a copy of my trust document ( which I had provided to the branch on XX/XX/XXXX ), the " Net Worth of Entity, '' a " Beneficial Ownership Declaration form, '' " Source of Wealth provided for Self-Employment, '' and " Annual Personal Income from Self-Employment. '' He told me that if I did not provide this information my accounts would be closed. He confirmed this with an e-mail. 

On XX/XX/XXXX, I visited the branch and met first with a personal banker, XXXX XXXX, and then the branch manager, XXXX XXXX, who advised me that if I did not provide this information my accounts would be closed. 

On XX/XX/XXXX, I wrote to XXXX XXXX XXXX, Chief Executive Officer, and requested that she provide me with the legal basis relied on by Citibank , N.A . for its request for my " Net Worth of Entity, '' " Source of Wealth provided for Self-Employment, '' and " Annual Personal Income from Self-Employment, '' required or my account may be blocked to prevent transactions ; her e-mail address is XXXX. 

On XX/XX/XXXX, I received a call from XXXX XXXX XXXX, Financial Associate, Executive Response Unit, Citibank Client Services, XXXX XXXX XXXX, XXXX XXXX, Texas XXXX, ( XXXX ) XXXX, who indicated that Citibank , N.A . is relying on the USA Patriot Act and Bank Secrecy Act of 1970 in its continued request for my " Net Worth of Entity, '' " Source of Wealth provided for Self-Employment, '' and " Annual Personal Income from Self-Employment '' as a condition to continuing our relationship. 

On XX/XX/XXXX, I wrote to XXXX XXXX XXXX and requested that he please provide me with the specific language used in the USA Patriot Act and Bank Secrecy Act of 1970 to support their decision. I copied XXXX XXXX XXXX, Chief Executive Officer, and XXXX XXXX XXXX, General Counsel and Corporate Secretary ; his e-mail address is XXXX. 

Nothing in the USA Patriot Act or Bank Secrecy Act of 1970 requires Citibank , N.A . to collect " Net Worth of Entity, '' " Source of Wealth provided for Self-Employment, '' and " Annual Personal Income from Self-Employment. '' None of the fourteen financial institutions I have accounts with have had the temerity to request this information, except Citibank , N.A . 

On XX/XX/XXXX, I again wrote to XXXX XXXX XXXX, and enclosed copies of a Citi Trust or Estate Beneficial Ownership Verification, my California Driver License ( front and back ), and Schedule A of my revocable living trust. I indicated the source of my self-employment income, that the I do not believe the USA Patriot Act and Bank Secrecy Act of 1970 require me to provide Citibank with the amount of income I receive, and I do report all income to the Internal Revenue Service and Franchise Tax Board. I copied XXXX XXXX XXXX, Chief Executive Officer, and XXXX XXXX, General Counsel and Corporate Secretary. 

On XX/XX/XXXX, I received a call from XXXX XXXX, Citi, XXXX XXXX XXXX, XXXX, Missouri XXXX, ( XXXX ) XXXX, who represented himself as an " Analyst in the Consumer Business Support Unit, '' but his XXXX account shows he is an Anti-Money Laundering Operational Risk Analyst II. He requested further information regarding my " source of wealth and " annual income from self-employment. '' On XX/XX/XXXX, I received a fax from XXXX XXXX XXXX in which he indicated " Having your information on file is a requirement of a federal regulation known as the Bank Secrecy Act, which is designed to help monitor for and protect against certain types of fraud and the flow of illegal funds around the world. While the questions we ask are not explicitly written in the regulations, I assure you that our XXXX XXXX is in line with regulatory expectations. As indicated in the enclosed letter dated XX/XX/XXXX, your accounts may be blocked on XX/XX/XXXX, if we do not receive the information requested. The information still needed to complete the XXXX review associated with your Trust accounts is the " Net Worth of Entity '' and " Annual Personal Income from Self-employment. '' On XX/XX/XXXX, I wrote to XXXX XXXX XXXX that Citi is well aware that it has been provided with all of the information needed to complete the Know Your Customer ( KYC ) review of my Trust account, and is also well aware that the Bank Secrecy Act of 1970 does not require it to collect the requested information ; XXXX. " Net Worth of Entity '' and " Annual Personal Income from Self-employment. '' Why would I want to continue to do business with Citi, when Citi clearly does not wish to continue to do business with me? 

On XX/XX/XXXX, I again visited the XXXX branch, and XXXX XXXX, the teller, closed my accounts. I deposited the money in another financial institution who I have had a relationship with for 29 years. 

Citi 's behavior, its letter to me dated XX/XX/XXXX, e-mails dated XX/XX/XXXX, XX/XX/XXXX, and XX/XX/XXXX, and telephone calls on XX/XX/XXXX and XX/XX/XXXX, deeply offends me.

Company public response: Company has responded to the consumer and the CFPB and chooses not to provide a public response
Company response to consumer: Closed with explanation