Does CIP apply to accommadator accounts? We open a lot of these accounts for lawyers. WE have all the CIP information on the lawyers.

Could you please define accomodator account. Thanks

One example of an accommodator account (note spelling) is an account for funds held by a trusted third party (such as an attorney) when an individual is trying to complete a "1031" exchange of property under the Internal Revenue Code and the timing for the sale of one property and purchase of the replacement property don't coincide. The IRS has special rules for handling funds in such cases in order for the taxpayer to be able to use the benefits of a 1031 (like property) exchange.

I didn't understand the reference either...here's a prior thread on 1031 exchanges. The qualified intermediary (accomodator if you will) is the fancy equivalent of an escrow agent and is the "customer" for CIP purposes. Depending on who is responsible for information reporting, you may need the name, SSN and address of the seller as well as a W-9 or its equivalent.

Would the CIP and OFAC be on the attorney or the 1031 (owner of funds) or both?