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September 22
FinCEN's Beneficial Owners Proposal: What It Can Mean for You;
Sonja Kriegsmann and John Burnett

September 23
Bankruptcy 101;
Sam Ott

September 30
Revised Escrow Rules - Review and Update;
Jack Holzknecht and Mary Beth Guard

October 7
CRA - Digging for Credit;
Patricia Cashman

October 8
Applicants and Applications: Knowing the Players and the Rules;
David Dickinson

October 15
MasterCard and Reg E: Basic Debit Card Investigations;
Brian Crow



Topic Options
#1695605 - 05/03/12 05:45 PM CIP Requirements for LLC
The Real Mobo Offline
100 Club

Registered: 04/24/06
Posts: 237
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 Online
Power Poster

Registered: 10/01/09
Posts: 3386
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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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: The Real Mobo]
Kathleen B Online

10K Club

Registered: 12/27/00
Posts: 17478
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: The Real Mobo]
rlcarey Offline
10K Club

Registered: 07/16/01
Posts: 50035
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: The Real Mobo]
BSA all the way Offline
Member

Registered: 01/19/11
Posts: 71
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: 237
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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