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#384487 - 07/12/05 07:18 PM CIP of Financial Plans
Belle Offline
Junior Member
Joined: Feb 2004
Posts: 43
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?

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#384488 - 07/14/05 08:46 PM Re: CIP of Financial Plans
Belle Offline
Junior Member
Joined: Feb 2004
Posts: 43
I am moving this back up to the top to see if anyone has an answer. I need to know whether a financial plan proposed to the customer triggers CIP. As I stated above, I feel that this is not an "account" because a "formal banking relationship" is not being established. Any guidance would be greatly appreciated.

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#384489 - 07/15/05 11:31 AM Re: CIP of Financial Plans
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
You are correct. Until the person opens an account with you they are not a customer.
I would also look at the wording in your BSA policy to see how your institution defines a customer and ensure that the two match.

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#384490 - 07/15/05 09:27 PM Re: CIP of Financial Plans
GregS Offline
100 Club
Joined: Jan 2005
Posts: 135
Sunny Florida
I think you have it correct also. This is how we approach potential clients in the Trust Department. We have proposed an agreement but until they accept they are not a customer and subject to CIP.
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