We have a loan that we purchased, we do not know these customers, they don't have a relationship with us. Do we ask them to come into the bank so that we can complete a CIP file on them? We purchased the loan from a company that is not required to conduct CIP, so I know they didn't do anything. What do we do??

Purchase assets are exempt from CIP. Refer to 31 CFR 103.121(a)(1)(ii)(B).

Doesn't that refer to purchased assets from other financial instiutions? I'm just worried because we bought this loan from a construction company (not a financial institution), so I know for a fact they did not do any sort of CIP. So we have a loan to a borrower we don't know and we know the construction company did not know them. I'm thinking we may just do some type of non-documentary procedures, just so we have some information for our files.

I don't see any reference to assets purchased from other institutions. You can read it yourself by clicking here.

Mr. Dickinson is correct. It doesn't matter from whom or where you purchased the asset. What does matter is that the purchase of the asset was not a customer initiated transaction. (Or was it in your case?) CIP applies to actions initiated by the customer. AR.

Okay. It was not a customer initiated transaction (in fact they don't even know we have their loan yet). Thanks AnonRegulator. It helps to clear it up for me.