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#412036 - 08/23/05 02:47 PM CIP Requirements for a Commercial Loan
Higgy1 Offline
Junior Member
Joined: Aug 2005
Posts: 43
I know you are required to obtain documents showing the existence of the corporation including the articles of incorporation and/or a government-issued business license.

Do you need to perform CIP procedures on the individuals that are signing the loan documents? Do you need to perform CIP procedures on the guarantors?

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#412037 - 08/23/05 02:57 PM Re: CIP Requirements for a Commercial Loan
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The regulation does not require you to perform CIP on mere signatories, only the customer. In this case, the customer is the corporation.

However, the regulation is no longer your primary source of direction. Your board of directors adopted a written CIP more than 18 months ago that sets out your bank's specific requirements. Your bank's CIP may enhance the requirements found in the regulation. Your CIP is the only reasonable resource to research for an answer.
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#412038 - 08/23/05 03:13 PM Re: CIP Requirements for a Commercial Loan
NLC Offline
Gold Star
Joined: Jun 2005
Posts: 287
Center of US
In the question and answers they state no you don't have to CIP authorized signers or guarantors BUT you need to look at our bank's risk assessment to determine if your bank will. Our bank does CIP on both. We want to know everyone we deal with.

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#412039 - 08/23/05 03:21 PM Re: CIP Requirements for a Commercial Loan
Coming to Grips Offline
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Joined: Jul 2004
Posts: 166
nebraska
In addition, be sure to CIP any co-makers on the loan. The co-makers could be individuals or other entities. Our lenders have forgotten that step lately.
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