I did a search on CIP, and couldn't find what I was looking for.

We have an account for a Homeowners Association. We have identified the HOA, but what about the signers on the account, are we required to do CIP on the signers or just OFAC?

I believe you do. Per the reg 103.121(C)(3)(i) Customer means: (B) An individual who opens a new account for (2)An entity that is not a legal person, such as a civic club.

KSinSeattle

A homeowners' association is generally a legal entity and, therefore, the "customer" for CIP purposes. The individuals involved should be able to answer the questions regarding their organization. Your written CIP adopted by your board of directors should indicate whether you perform CIP on mere signatories. Prior thread.

OK - for clarification - CIP (tax id, physical address, etc. etc.) for the HOA, but the signers are not required by law to give us the same information on themselves personsally?

The reason it's coming up - is that I have a couple of signers that do not want to give us their personal information, for whatever reason - I already have issues with "why not". That aside, is it law, that I have that personal information (tax id, physical address, dob)?

by the way - the signers ARE NOT owners, they are simply signers on the HOA account.

Anon #376261,
If the HOA is an entity, BSA/CIP regulations do not require you to obtain identifying information on a mere signatory. However, if the CIP adopted by your board does require you to ID signatories, then that is "the law" in your bank; i.e. you cannot waive the requirement just because they don't want to give you the info.