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August 5, 2015
HMDA – Beyond the Input
Patricia Cashman

August 11, 2015
ABCs of HSAs
Whitney Johnson

August 12, 2015
Part I: Flood Insurance - Everything You Need To Know (including June 2015 Rules)
David Dickinson and Jerod Moyer

August 13, 2015
Currency Transaction Report (CTR): Line-By-Line for Tellers
Deborah Crawford

August 18, 2015
Disaster Recovery Revisited: 5 Things You May Not Have Considered (for a while)
David Reed

August 20, 2015
Automated Monitoring Systems: Implementation to Validation
Brian Crow

August 25, 2015
MasterCard & Reg E Error Resolution
Brian Crow



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#1695605 - 05/03/12 05:45 PM CIP Requirements for LLC
CantBeShocked Offline
Gold Star

Registered: 04/24/06
Posts: 260
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: CantBeShocked]
Doug Hendrickson Online
Power Poster

Registered: 10/01/09
Posts: 3621
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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I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1695614 - 05/03/12 06:30 PM Re: CIP Requirements for LLC [Re: CantBeShocked]
Kathleen B Online


10K Club

Registered: 12/27/00
Posts: 19200
If your CIP program does not say it is required it is not required.
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Kathleen Blanchard CRCM "Kaybee"
Lending/CRA/HMDA/Mapping/Consulting
www.kaybeescomplianceinsights.com

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#1695639 - 05/04/12 07:47 AM Re: CIP Requirements for LLC [Re: CantBeShocked]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 54320
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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The opinions expressed are my own, take them or leave them.

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#1695667 - 05/04/12 08:35 AM Re: CIP Requirements for LLC [Re: CantBeShocked]
BSA all the way Offline
Member

Registered: 01/19/11
Posts: 74
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: CantBeShocked]
CantBeShocked Offline
Gold Star

Registered: 04/24/06
Posts: 260
Loc: MS
I agree with BSA All the Way but I needed what is "required" at this time. Thanks.
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