If the organization has a IRS tax ID, its a revenue agency. If the organization does anything in the name of "the IRC requires it" or in the name of "the Treasury regulations" require it, it is an agency of the IRS or the Treasury Department to the applicable extent. There was an old case where a private water company contractor was collecting information in connection with its billing practices or something like that and the court ruled that because the organization was doing allegedly in connection with a Federal law, the organization was acting as a Federal agency in doing so and was to be treated like a government agency in that specific act.
If a banker says he or she wants information to fulfill Treasury Regulations or any government this or that even because of the PATRIOT Act then the banker is a State or Federal agent and anything about it being their bank policy is sophistry--they are liable as if a public Federal or State agency for any breech of the law or injury, loss or harm they cause in the same manner as a Federal agency would be. If they claim greater powers than the statute, law or regulation then they could be liable for fraud. However, they might try to sell you "its bank policy" Koolaid before you walk out the door.
If they don't know or do know and pretend not to then they might be subject to criminal or civil liability and might also be subject to ouster, revocation or suspension of licensing or the like for incompetence or the like (you know kinda like how they suspend driver licenses?). Fraud, maybe?So, as agents of the principal/trustee, they should know HOW to handle getting a credit from the trustee, right?
The Treasury Department or a State or Federal Attorney General might be able to help with that.So, let's hold them accountable, and if they fail to perform, that is outside the scope of their principal/agent agreement, and then can be held liable.