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CIP on Safe Deposit Box Signer
Answer by John Burnett and David Dickinson, BOL Guru
Guru Bios
Question:
Is it necessary to obtain a CIP on a signer to a safe deposit box?
Answer by John Burnett:
That's not possible for us to answer. Although authorized signers are not considered "customers" by the CIP regulations at 31 CFR 103.121, you have to know what your own institution's board-approved CIP has to say on the subject. If your policy calls for completing CIP on such individuals, you have to do it.
Answer by David Dickinson:
Whether it is a safe deposit box or a checking account makes no difference to the answer to this question.
First published on BankersOnline.com 4/09/07
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