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#366349 - 06/01/05 04:39 PM CIP & Qualified Intermediary
sclark Offline
New Poster
Joined: Jun 2005
Posts: 2
florida
We have an real estate attorney's firm as a new customer and they want to open multiple accounts acting as the intermediary for their clients for 1031 exchanges. Who do we conduct CIP for, the client, whose name & TIN will be used, or the attorney's office rep who is appointed the intermediary for the client?

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BSA/AML/CIP/OFAC Forum
#366350 - 06/01/05 06:45 PM Re: CIP & Qualified Intermediary
Coming to Grips Offline
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Joined: Jul 2004
Posts: 166
nebraska
You need to determine who has authority and control over the account. If the attorney is the one with authority and control, then you CIP the attorney. If the attorney's client has authority and control, then you CIP the client.
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#366351 - 06/02/05 12:03 AM Re: CIP & Qualified Intermediary
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
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