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A Banker's Guide to Virtual Currency
Andrew Beal

April 24
BSA/AML Compliance: Writing the SAR Narrative
Ken Golliher

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HSA Basics
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April 29
Required Training for Loan Originators
Mary Beth Guard and Jack Holzknecht

May 13
Overdraft Practices in Today's Regulatory Environment
John Burnett

May 14
Reg E Claims - Allocating Liability Correctly
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#1695605 - 05/03/12 05:45 PM CIP Requirements for LLC
The Real Mobo Offline
100 Club

Registered: 04/24/06
Posts: 220
Loc: MS
I know that CIP is not "required" for authorized signers on a corporation. What about authorized signers on a Limited Liability Company (LLC)? Is CIP required - not suggested - required?

On a side note - if you think this question is dumb and are tempted to post a snarky answer, please don't. I'm deadly serious and need help!

Thanks.
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BSA/AML/CIP/OFAC
#1695611 - 05/03/12 06:06 PM Re: CIP Requirements for LLC [Re: The Real Mobo]
Doug Hendrickson Offline
Power Poster

Registered: 10/01/09
Posts: 3257
Loc: NE New Mexico
Since the regulation calls for CIP of your customer and the LLC is the legal entity that would be your customer, I would only CIP the LLC.

Just as a clarification, we generally ask for identification (ssn, dl, etc.) for authorized signers, just so that we can assure ourselves that they are who they say they are and 'tie' them to the account, but this is not considered as part of CIP.


Edited by Doug Hendrickson (05/03/12 06:10 PM)
Edit Reason: Clafification
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#1695614 - 05/03/12 06:30 PM Re: CIP Requirements for LLC [Re: The Real Mobo]
Kathleen B Online

10K Club

Registered: 12/27/00
Posts: 16553
If your CIP program does not say it is required it is not required.
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#1695639 - 05/04/12 07:47 AM Re: CIP Requirements for LLC [Re: The Real Mobo]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 48538
Loc: Galveston, TX
However, beneficial ownership is a hot button with FinCEN and you might want to review this advanced notice of proposed rule making issued by FinCEN in Feb 2012:

http://www.gpo.gov/fdsys/pkg/FR-2012-03-05/pdf/2012-5187.pdf
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#1695667 - 05/04/12 08:35 AM Re: CIP Requirements for LLC [Re: The Real Mobo]
BSA all the way Offline
Member

Registered: 01/19/11
Posts: 68
Rules or not, my feeling is that as an organization, I want want to know who I am doing business with..plain and simple. The world is too crazy to look for technical ways around it.
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#1696164 - 05/04/12 04:59 PM Re: CIP Requirements for LLC [Re: The Real Mobo]
The Real Mobo Offline
100 Club

Registered: 04/24/06
Posts: 220
Loc: MS
I agree with BSA All the Way but I needed what is "required" at this time. Thanks.
_________________________
Persistence can grind an iron beam down into a needle - Chinese proverb

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