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#1277099 - 10/29/09 07:18 PM CIP on individuals doing business
6231956 Offline
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Joined: Oct 2009
Posts: 75
Is it necessary or required to do a CIP on an individuals DBA business/Sole Proprietor Account?

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#1277102 - 10/29/09 07:24 PM Re: CIP on indivudauls doning business 6231956
Dallas Fan Offline
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Joined: Feb 2008
Posts: 219
RIC
Absolutely. The info you obtain would be the individuals identifying information. SSN, DOB, Phys. address, and identification (generally a drivers license, State issued ID, or passport).

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#1277105 - 10/29/09 07:31 PM Re: CIP on indivudauls doning business Dallas Fan
6231956 Offline
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Joined: Oct 2009
Posts: 75
So you only do the individual or do you CIP both individual and the business?

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#1277110 - 10/29/09 07:38 PM Re: CIP on indivudauls doning business 6231956
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
You need to CIP the individual and obtain info on the business (many banks obtain business licenses, etc) so you understand the person you are doing business with and know what kind of activity to expect. So, CIP and Customer Due Diligence at least at a basic level. More may be needed based upon what you find out.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1277126 - 10/29/09 08:02 PM Re: CIP on indivudauls doning business 6231956
Elwood P. Dowd Offline
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Posts: 21,939
Next to Harvey
According to the regulation, there is only one "customer," the individual. On a good day, the "business" is nothing but a figment of somebody's imagination.

A banker in Arkansas explained it to me that the name of the sole proprietorship was of no more importance than the owner's nickname and she would have put that in the account title too if he asked her too. wink

However, as Kaybee says, its the banker in you that wants to verify that this is a bona fide account title. You want assumed name certificates, business licenses, tax certificates, or any other government issued document that indicates this is a legitimate business enterprise.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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#1277428 - 10/30/09 02:04 PM Re: CIP on indivudauls doning business Elwood P. Dowd
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
And, if you ever are tempted to exempt this business account from CTR filing requirements, you will need documentation that it is a commercial enterprise that "is registered as and eligible to do business within the United States or a State."
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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