Anyone have experience with NPO's? Are we required by CIP to obtain information on individuals who are signing on behalf of an NPO? These people typically have no ownership in the business as they are elected officers by the NP Board.

TIA

We CIP everyone that is involved, i.e. everyone that is going to sign on the account.
You could have a for profit company with non-owners as signers and you would still CIP them.
Same principle.
The reg requires that you obtain 4 pieces of information on each 'customer'.
Your policy has to define how you would treat certain types of customers, i.e. you may require only one ID vs. two for non profits or elderly, but you still have to form a 'reasonable belief' that you know the customer.
Because of terrorist financing, all non-profit accounts are looked at by Examiners, so even if it is a local non-high risk group, I would still ensure that CIP is completed.
Hope this helps you.

We follow our normal CIP for business accounts. At our bank we do not require the SSN/TIN of the signers, but we do verify via some form of photo ID that they are the individual who is authorized on the corporate resolution. Hope this helps.

You have a couple issues to resolve:

1) Is the NPO a "person" as defined by CIP? Although it's not fool-proof, one easy test is, "does the NPO have a TIN?" If they have a TIN you're probably dealing with a "person" as defined by CIP. If not, move carefully. You may be dealing with a guy who wants an account for his golf league which has no formal or legal structure.

2) If the NPO is a "person" then you must review your own CIP procedures. While it's true that the Reg does not require you to perform CIP on authorized signers, some FI's wrote their policies such that they are required to do full CIP. For example: in our data processing equipment we don't have the option of creating a common file for a non customer so consequently if we don't get SSN, DL, etc. on authorized signers they keep showing up on exception lists. Our CIP policy doesn't require full information on authorized signers but if we want to keep data processing happy we'd better get it!

In summary, NPO's are no different than any other business for CIP purposes.

Your responses were all helpful...thank you!!