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#370831 - 06/08/05 03:30 PM CIP requirements for Government Entities
Comply Offline
Gold Star
Joined: Oct 2003
Posts: 291
What is the minimum CIP for Government Entitites? Or are they exempt?
Last edited by John Burnett; 06/08/05 03:43 PM.
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#370832 - 06/08/05 03:50 PM Re: CIP requirements for Government Entities
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
From 31 CFR 103.121(a)(3)(ii):
"Customer does not include:
****
(B) A person described in ยง 103.22(d)(2)(ii)-(iv);"

From 31 CFR 103.22(d)(2)(ii) and (iii):
"For purposes of this section, an exempt person is:
****
(ii) A department or agency of the United States, of any State, or of any political subdivision of any State;
(iii) Any entity established under the laws of the United States, of any State, or of any political subdivision of any State, or under an interstate compact between two or more States, that exercises governmental authority on behalf of the United States or any such State or political subdivision;"

If the customer that you're looking at falls within 103.22(d)(ii) or (iii), the CIP regulation considers that customer exempt (it's not a customer for the purposes of the rule).

However, if your bank's board-approved CIP doesn't describe the customer as exempt, you have to comply with the bank's rule and do the ID verification routine.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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#370833 - 06/29/05 09:26 PM Re: CIP requirements for Government Entities
Ann Offline
Platinum Poster
Joined: Jul 2001
Posts: 564
South Carolina
Does someone have examples of CIP requirements (documents) for government entities or public funds according to their Bank's CIP policy if these are included?

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#370834 - 06/30/05 11:50 AM Re: CIP requirements for Government Entities
Dolly Nugent Offline
Diamond Poster
Dolly Nugent
Joined: Nov 2000
Posts: 1,820
Southern California
Ann,

Consider modifying your CIP procedures to incorporate the exemption. I think this would be FAR easier than trying to figure out what documentation you need. You will only frustrate your bank officers by making this process harder than it has to be. (It's not easy to get a government entity to come to your bank.)
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Dolly Nugent
CRCM
Opinions expressed are my own.

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