Our core system is Jack Henry and the system requires a DOB and SSN on each authorized signer on an account. The Patriot Act states that a governmental unit is not a customer. We have a county hosptital wanting to open a public fund checking account but they are very reluctant to give us this information on the authorized signers. The account officer says we should "think outside the box" and find some way around this.

Are there any Jack Henry banks out there that have had push back from a governmental unit with this. If so, how did you handle it?

The regulation does exclude government entities from the definition of "customer." That has no bearing here.

You're talking about requiring identification from a "mere signatory" on an account. If that is required, then it is required by your CIP, not the regulation. If you want to alter your CIP to say you do not require identification from signatories if the customer itself is exempt from CIP, you may do so. It may ease their discomfort, but it won't be much of a decision from a banking standpoint - your bank should be able to identify signatories, pure and simple.

While I agree with the practice, it seems a bit paternalistic that your software would "require" the information. You may want to discuss it with the vendor or see if the answer materializes below.

My experience with people who want others to "think outside the box" is not good.

If your system is requiring a DOB and SSN, I suspect that your bank has set those fields as "required", rather than "optional". The field parameters can be changed if the bank chooses to do so.

You could make the fields optional and monitor by generating a report identifying a list of any new CIF record created where the relationship is NOT a signer (or any other relationship where you do not require the DOB and/or SSN). That will enable you to follow up to correct the record of a primary, joint owner, etc.