Posted By: LauraL
CIP on Loan Purchased? - 06/27/05 07:02 PM
We have a loan that we purchased, we do not know these customers, they don't have a relationship with us. Do we ask them to come into the bank so that we can complete a CIP file on them? We purchased the loan from a company that is not required to conduct CIP, so I know they didn't do anything. What do we do??
Posted By: Anonymous
Re: CIP on Loan Purchased? - 06/27/05 08:47 PM
Purchase assets are exempt from CIP. Refer to 31 CFR 103.121(a)(1)(ii)(B).
Posted By: LauraL
Re: CIP on Loan Purchased? - 06/28/05 03:06 PM
Doesn't that refer to purchased assets from other financial instiutions? I'm just worried because we bought this loan from a construction company (not a financial institution), so I know for a fact they did not do any sort of CIP. So we have a loan to a borrower we don't know and we know the construction company did not know them. I'm thinking we may just do some type of non-documentary procedures, just so we have some information for our files.
I don't see any reference to assets purchased from other institutions. You can read it yourself by clicking
here.
Posted By: AnonRegulator
Re: CIP on Loan Purchased? - 07/05/05 02:13 PM
Mr. Dickinson is correct. It doesn't matter from whom or where you purchased the asset. What does matter is that the purchase of the asset was not a customer initiated transaction. (Or was it in your case?) CIP applies to actions initiated by the customer. AR.
Posted By: LauraL
Re: CIP on Loan Purchased? - 07/05/05 03:31 PM
Okay. It was not a customer initiated transaction (in fact they don't even know we have their loan yet). Thanks AnonRegulator. It helps to clear it up for me.