Click to return to BOL home page
Banker Store eCard Exchange Vendor Connect Career Connect Learning Connect Bankers Information Network
Home Compliance Lending Operations Security Marketing Technology/eBanking
Top Stories Bankers' Threads BOL Conferences CrimeDex Em@il Education FREE Briefings Record Retention

   

















    Site Map

    Our Sponsors

    Home


Print Friendly! Email This Article! Discuss NOW!

CIP Slack: Burdens you escape
by Mary Beth Guard, BOL Guru

After looking through the long list of things you must do, it should come as a pleasant surprise that there are at least a dozen CIP burdens the regulators have expressly relieved you from. Here, we examine twelve things you are not required to do under the final rules.

You do NOT have to:
  1. Make a copy of IDs;
  2. Authenticate or validate documents provided by customers, BUT if a document shows obvious indications of fraud, you must take that into consideration in determining whether you are able to form a reasonable belief that you know the customer's true identity;
  3. Verify the identity of signatories;
  4. Verify the identity of existing customers, so long as you can form a reasonable belief that you already know their true identity;
  5. Establish the accuracy of every element of identifying information obtained, as long as you establish the accuracy of enough of the information to form a reasonable belief you know the true identity of the customer;
  6. Look through a trust to verify the identities of beneficiaries;
  7. Look through escrow or similar accounts to verify the identities of beneficiaries;
  8. Look through a deposit broker's account to determine the identity of each individual sub-account holder;
  9. Verify the identity of a minor, when an account is being opened by an adult on behalf of a minor;
  10. Verify the identity of an incapacitated person, when an account is being opened on their behalf;
  11. Verify the identity of any entity that is not a legal person.
  12. Verify identity on publicly traded companies, government agencies and instrumentalities, and other financial institutions regulated by a Federal functional regulator.

    The original version appeared in the April 2003 edition of the Oklahoma Bankers Association Compliance Informer.

    First published on BankersOnline.com 9/8/03


    Home | Compliance | Lending | Operations | Security | Marketing | Technology | eBanking
    BOL Archives    Privacy Policy    Important Disclaimer   Recommend This Site !   Contact Us


    BankersOnline is a free service made possible by the generous support of our advertisers and sponsors. Advertisers and sponsors are not responsible for site content. Please help us keep BankersOnline FREE to all banking professionals. Support our advertisers and sponsors by clicking through to learn more about their products and services.