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CIP Requirements- 4 Basic Criteria on all Signers?
Answer by John Burnett, BOL Guru
Guru Bio
Question: Regarding CIP requirements for business accounts, do we need the 4 basic criteria for all signers on the account?
Answer: If the business is a separate legal entity, the CIP regulations do not consider the signers as customers. Therefore, you would apply your CIP to the business and not to the signers. However, if your institution has adopted a Customer Identification Program (CIP) that requires that you obtain the "big four" elements of ID on all signers for an account, you are required to follow that requirement. If the requirement causes problems for the bank (as it has for some), it should be looked at again with a view toward adjusting it (don't forget the change will require board approval).
First published on BankersOnline.com 7/02/07
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