Posting CIP Notices in Branches
by Mary Beth Guard, BOL Guru Guru Bios
Question: If we decide to just post our CIP notices, instead of giving oral or written notice to customers, can we follow a "one per branch" rule?
Answer: The rule is fairly flexible about giving notice of your identification requirements. You can give it orally, you can provide it in writing. You can even post a sign. If you post a sign, however, you need to understand that one per branch is probably not going to be sufficient. The requirement is that the notice be given in a manner reasonably designed to ensure that a customer is a) able to view the notice; or b) is otherwise given notice, before opening an account.
Take a little trip through your branch. Follow the path that a customer is likely to follow when the customer comes in to apply for a loan, purchase a CD, open a deposit account, rent a safe deposit box. Is there any one location that you can say, with certainty, is a spot where a sign would likely be seen by each customer coming in to open an account? Some institutions are putting a standing sign inside each entrance. Others are putting the signs on or by the desk of every new account representative, loan officer, and safe deposit box attendant. If you combine your deposit-side notice with the Member FDIC logo, it can do double duty. On the loan side, you can use a version that has the CIP notice coupled with the Equal Housing Lender doghouse.
The original version appeared in the July/August 2003 edition of the Oklahoma Bankers Association Compliance Informer.
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