In the Office of Thrift Supervision's CIP "A Staff Summary and Answers to Questions," the Treasury writes, "In addition to collecting the required information, thrifts must verify the identity of the customer using the collected information" (pg 4 of 9). I thought that the identification number collected (SSN, passport number, etc.) was different from the documents used to verify the identity. If you obtain a driver's licence number as an identification number, I would think you shouldn't (?) verify his/her identity with the same document... Please explain.
There have been numerous threads regarding CIP policy versus procedures. Some threads state that the CIP procedures need to have Board approval whereas others say a general overview of procedures is needed. My question is 1)do the procedures really need to go to the Board for approval and 2) how in depth do these procedures need to be? Could we keep the policy separate from the procedures or do they really need to be a single document?
In opening corp, LLC, and partnership accounts, we do Telecheck and CheqSystems on the principals. We have them sign an authorization. We are now considering not doing that process. We would still require the appropriate documentation and could verify with the Secretary of State. I would like to know what your opinion is regarding verifying through CheqSystems and Telecheck or similar systems of the principals for these business accounts.
Commonly cited violations have long been a source of important information for the design and management of compliance programs.
We are down to the wire for adoption and implementation of a customer identification program. There has been a lot of talk and more worry about what is or should be involved.
How does the new Patriot Act regarding CIP address closed accounts? What I mean is if a customer has closed an account but still is on our operating system with all information, are they considered a new customer if they come in to open a new account?
The CIP ruling did not specifically address the mortgage lenders. How can we or when should we identify customers on mail applications, telephone applications or when the loan is being handled by a representative with a power of attorney and the borrower cannot be present?
Our bank accepts funds via wire transfer from a broker who places the funds with the bank on behalf of public school districts. The bank opens CDs with the funds in the name of the school district. What documentation will satisfy customer identification requirements?
Our bank is going to start offering online loan applications for customers to print, fill out and send in for home mortgages. Do we have to give any disclosures out on the Web site to customers printing up a loan application? We will also be taking applications for new accounts online. To stay in compliance with the CIP regulation, will they have to come into the bank for the account to be opened? Do we have to have the disclosures online or can they be given to the customer when the customer comes into the branch?