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Multiple Signers - ID All?
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Answer by Ken Golliher, BOL Guru
BIO AND CONTACT INFO
Question: We are a commercial bank with a large number of business accounts. Many of these accounts have numerous signers who are bookkeepers and the like with no authority or control. Are we required to collect the ID of these individual as well as those with authority and control? Or are we permitted to collect the only ID of those who are in authority/control of the company as demostrated on a corporate resolution or similar documentation?
Answer: The final CIP regulation requires you to obtain information and verify identity on the "customer," not the signatories. In examples where the "business" is an entity; e.g. corporation, general partnership, LLC, LLP, etc. the "customer" is the entity. You are only required to obtain information on and verify the identity of the entity when it opens a new account.
The law does not require you to identify the signers on an entity's account. Prudence might.
First published on BankersOnline.com 9/8/03
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