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#1143641 - 03/11/09 06:58 PM CIP on in-house escrow account
ComplyOhMy Offline
Platinum Poster
Joined: Dec 2005
Posts: 514
Lexington, Kentucky
Our bank is opening an account for an escrow account for a builder with two of our lenders as signers. What type of CIP would be required? Our policy does not address such a situation.

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BSA/AML/CIP/OFAC Forum
#1143646 - 03/11/09 07:02 PM Re: CIP on in-house escrow account ComplyOhMy
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Are you saying that your BANK is establishing an account as agent for a builder?
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#1143656 - 03/11/09 07:30 PM Re: CIP on in-house escrow account BrendaC
ComplyOhMy Offline
Platinum Poster
Joined: Dec 2005
Posts: 514
Lexington, Kentucky
We are holding this account in escrow. The checks are made out to the bank.

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#1143663 - 03/11/09 07:40 PM Re: CIP on in-house escrow account ComplyOhMy
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
The account owner is your bank. You document just as you would any other internal account. There is technically no CIP requirement.
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Life without Jesus is like an unsharpened pencil - it has no point.

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