Under CIP, if we have a current customer whose government issued ID has expired are we required to obtain a current ID before doing any transactions for that customer?
I just read your answer to a question concerning the definition for a permanent address. I have a specific question concerning determining a permanent address for CIP purposes. The bank recently has experienced customers wanting to open new accounts who are living in campers, the local motel or with family in the area until they can find a place to live. What do we list as permanent physical address? Due to the nature of the business they are in , many have a previous address different from the address on a drivers license etc.
I have been instructed to obtain a "Secretary Signature" on all Business Checking accounts. Is this the law? Many accounts today do not have Secretary's. Please advise if this is a Compliance mandated requirement or an Operations Requirement or neither.
A new customer has presented his driver's license for CIP and a credit report is obtained. The credit report has his new address and "NO" address discrepancy red alerts show. Does this mean an address discrepancy has not occurred and the account can be opened using the address obtained?
One of our loan officers did a loan for a new customer who has recently been married. The loan officer did the loan in the Customer's married name but took her ID with her maiden name. Her CIP will not match the name on the loan. Will the bank be out of compliance with the examiners?
The husband of a long time customer of the bank, is using her account to deposit large dollars in postal money orders, cash, his social security check and wires for services he provides. The money is then Paypal'd out. We have no idea of the source of these funds. Her paycheck is an ACH not in questions. We have been filing SAR's for a year. Should we leave the account open?
We need some clarification on collection and retention of drivers licenses, for both CIP and loans. I am under the impression that while not mandatory, a black and white copy may be obtained and retained separately in a secured location (example-ring binder, file cabinet in vault). Is that correct?
What are the proper procedures to CIP for an attorney-in-fact (AIF) under a power of attorney? My question comes from an instance where we have a CIP grandfathered Amish customer and they would like to add someone to their account that doesn't have a TIN and refuses to get one. They went to an attorney to get around the CIP restriction and made him an AIF so he wouldn't have to go through the normal CIP process. Is an AIF considered a customer under 103.121?
I come across an account that had been changed to a Trust Account from a joint account. The joint account had the father, son and daughter-in-law. The account was changed over to a Trust account which included the Trust owner and two trustees (the sons). The account was not closed just maintenanced. My question: Shouldn't the joint account have been closed and a new account opened since there was a removal of one owner and an addition to the trust or at least a relinquish form removing the one owner?
Is a charged-off deposit account considered an on going relationship for CIP purposes? Can we re-open a charged-off account without re-CIP?