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#355650 - 05/04/05 08:20 PM CIP and Attorneys Closing Commercial Loans
Kay Offline
100 Club
Joined: Mar 2004
Posts: 248
Midwest
I have just been informed that we will begin having Attorney closed loans where the actual commercial borrowers do not come to the bank. Does anyone have experience with this particularly in regard to CIP procedures?

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#355651 - 05/05/05 06:09 PM Re: CIP and Attorneys Closing Commercial Loans
renniks Offline
Diamond Poster
renniks
Joined: Sep 2003
Posts: 2,162
New England
Kay: We have the same situation with residential loans. What we do is "non-documentary" I.D. verification during the loan underwriting process and provide the closing agent with our "documentary" form for them to fill out and note the type of ID, issue date, etc. We list the types of acceptable ID's on the form. We have been doing this for a year or so, and once we got the attorneys used to the process, it has worked fine.

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#355652 - 05/06/05 03:24 PM Re: CIP and Attorneys Closing Commercial Loans
murphysgirl Offline
Gold Star
murphysgirl
Joined: Oct 2004
Posts: 269
Home of the Red Sox
Same here Kay. We just went through FCIC Compliance, Safety and Soundness, and the State Exam (all at the same time and nobody wonders why I have white hair and drink, just kidding about the white hair) I can e-mail you my form if you want- we interpreted CIP's definition of a new customer for our loan department as when we close a loan and dispurse funds they become a new customer therefore we gather ID info at closing through the attorneys. The key here is auditing the attorneys for compliance with our procedures, and we do on every file closed. We also have an existing customer exemption on the form. Let me know if you would like to see if my form will suit your needs.
_________________________
Humility about how little I know has encouraged me to listen more carefully and more wisely.
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