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December 3, 2014
Overdrafts: Latest Regulatory Feedback, Guidance & Best Practices Webinar
David Dickinson and Jerod Moyer

December 4, 2014
Freebies, Bonuses and Contests
John Burnett and Andy Zavoina

December 9, 2014
Bankruptcy: Creditor Do's and Don'ts
Sam Ott

December 10, 2014
Branch Audits: What Is Going On Out There?
Patricia Cashman

December 17, 2014
Integrated Disclosures - An Implementation Strategy
Mary Beth Guard and Jack Holzknecht

December 18, 2014
Loan Review Best Practices for a Community Bank
Bob Fritzlan

December 19, 2014
PREPAID PRODUCTS - Understanding the CFPB Proposal
John Burnett



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

Registered: 04/24/06
Posts: 245
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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Persistence can grind an iron beam down into a needle - Chinese proverb

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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: 3417
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: 17710
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: 50645
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: 72
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: 245
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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