Would failure to collect beneficial ownership information at account opening (CDD) or a reason for not needing CDD certification of beneficial ownership be considered a CIP exception?
When addressing Beneficial Ownership-Statutory Trusts, what is the best way to discern a trust that is a "statutory trust created by a filing with a
Secretary of State or similar office"? We have questions regarding how to tell the difference between a regular family trust and a business trust.
Do you need to complete a new CIP form for a change of address?
What is the proper identification for cashing checks or making deposits?
If a client has a Social Security card stamped for work only, can that be used for opening accounts in a bank?
When opening accounts for the City (Police, Fire Department, etc.) what documents are we required to collect? Here is why I ask:
“Earlier this week the city of XYZ opened a new savings account. They have been a customer since 1977, therefore we don’t have all the paperwork that is now required. This account was brought in by the Chief of Police and the Warrant Officer saying that it needed to be a new account under the “CIF” of the City of XYZ, but needed to be worded titled “The State of TX vs ….. defendant.” There has been an account like this in the past, the defendant is in jail and it's confiscated funds. My question is, what all documents do we need?”
I have a new customer who has a single member entity that is disregarded for tax purposes (rental income and expenses are reported on personal tax return), but has been assigned an EIN separate from his SSN. The entity is 12 years old and he has misplaced his letter from the IRS verifying the LLC's EIN. What is the easiest way to document this to comply with CIP procedures? Can I take his and his accountant's word that the EIN is correct?
Would a student identification card be an appropriate ID for a minor account if they dont have a drivers license or state ID? The parent/guardian is on the account with them and we do have sufficient ID for them.
We have recently acquired two branches of another bank, along with the customers base from those two locations. We are wondering about the CIP violations that we seemed to have "inherited" from these two locations. Are these now our issues or does it fall under the bank of account opening? We are the second bank to own these two particular locations. Any information or guidance is appreciated.
Where can I find regulatory citation regarding the retention of copy of driver's license from CIP process on a loan application? Is it okay to retain in loan file or separate CIP file? Our concern is possible fair lending implications.