Our bank has a Financial Planning department that proposes financial plans to individuals who may or may not have accounts with our bank. The individuals typically solicit such plans from other financial institutions as well and then selects an institution to use. I believe that CIP does not apply to these individuals as an "account" or "formal banking relationship" is not being established. However, in the event the individual selects the plan proposed by our bank, CIP would be obtained from the individual(s) at account opening. Does anyone have any thoughts on this issue?