My bank wants to start opening joint deposit accounts, even though both signers are not present. The are willing to send the signature card home to be signed by the non-present account holder and would only require a photo copy of the front and back of the DL to be submitted when the signature card is returned. The TIN would have to be verified using other means, such as third party verification. Being on the security side, I am extrelemy biased against this practice. Will this violate the general requirements of CIP?

I bank with a bank that will open accounts if you provide general personal information and a copy of your drivers license. I'm pretty sure you can without violating CIP but I don't know where you find that in the law.

This practice may be difficult to defend in light of the requirement to "establish a reasonable belief that you know your customer's true identity." While CIP does not require banks to verify the authenticity of documents provided, sound banking practices may encourage you to do so.

We have a lot of requests to mail away cards and rather than sy "NO" after CIP kicked in we came up with the following.

We require notarization of the signature card and a legible copy of DL for any card which leaves the office. Our account opener is responsible for a signature comparison with card & DL and must initial it when it returns. It was the only thing we could think of to establish identity and responsibility for identity. We use a third party for identification verification.
This just went past a FDIC exam.

CIP is risk based and if your Bank policy says it is OK and your Board has decided it is willing to take the risk, I guess you can do it, but I would have to agree with GuitarDude that 'a reasonable belief that you know your customer' would be hard to defend in that scenario.

Is this a true statement based on the reg for additional verification?

If a financial institution is unable to verify the identity of persons other than an individual, such as a corporation or other legal entity, using documentary or non-documentary methods, it must either:

-Choose not to open the account; or
-Collect and verify identifying information on individuals with authority or control over the account, such as signatories

Reg:
(C) Additional verification for certain customers. The CIP must address situations where, based on the bank's risk assessment of a new account opened by a customer that is not an individual, the bank will obtain information about individuals with authority or control over such account, including signatories, in order to verify the customer's identity. This verification method applies only when the bank cannot verify the customer’s true identity using the verification methods described in paragraphs (b)(2)(ii)(A) and (B) of this section.

I say no, because the verification of signatories is supposed to be an additional risk-based method along with whatever documentary/non-documentary methods the bank has established. To only have signatory verification who be a violation of the reg?

I agree with you.
The entity is a separate person and CIP applies to the entity.