Disclosing transaction limitation due to CIP
by John Burnett Guru BIOS
Question: With all the reading and research I did on CIP prior to writing our policy/procedure, I don’t
believe I missed anything; however, the question has now been raised with reference to an article on the Compliance Headquarters website (see below).
If, within our CIP policy/procedure, we have identified transaction limitations that will be imposed if the bank
chooses to open an account prior to completing all identity verification, do these limitations need to be disclosed in our TIS and Reg E disclosures?
We recommend not opening until verification is complete, but provided the option to do so if necessary.
Here is the article I am referring to: http://www.complianceheadquarters.com/AML/AML_Articles/customer_information_programs.html
Answer: I have reviewed the recommendations offered by Bankers Systems in their article. They appear wellfounded
and accurate. It is appropriate to disclose these temporary restrictions at account opening in such cases.
The original version appeared in the September/October 2004 edition of the Oklahoma Bankers Association Compliance Informer.
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