When you issue a corporate credit card to an agent of the corporation, the corporation is your customer, not the individual. Whether or not you should require and verify identity information from the individual for CIP purposes will depend on your institution's board-approved CIP policy and any implementing procedures.
Last edited by John Burnett; 05/14/09 04:19 PM.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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