08/13/2012
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?
07/30/2012
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?
07/09/2012
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?
06/04/2012
CIP requires that we obtain the customer's tax identification number. Is it required to verify the customer's tax identification number? In other words, should the bank require the customer/or business to provide proof of their tax identification number?
05/21/2012
I have been told by examiners and at seminars in the past that if an existing customer alters (ex. adds a new person to the signature card, etc) or adds a new account then that existing account owner is no longer "grandfathered in" in regards to CIP and the necessary CIP information needs to be gathered at the of the change to the existing account or at the opening of the new account. Although "reasonable belief" is still present, the change to the account or the addition of the new account has changed the relationship, therefore the need to gather the CIP information. Is this standard practice for the industry?
10/10/2011
What documents are required for opening a Community/Volunteer Group? It's not a Corp. or an LLC and it has a Tax ID.
10/03/2011
I am trying to find a format to address a requirement from recent FDIC Examiners and have searched your website (and others) without finding what I need. Our BSA Risk Assessment “does not contain detail analysis of data obtained during the identification stage in order to assess risk.” Can you help me find a format for this?
08/22/2011
I'm new to BankersOnline.com and also to compliance. I am trying to find some training materials relating to the USA Patriot Act that I could potentially use as a model for staff training at our bank. Can you point me in the right direction?
06/20/2011
Our lenders have been meeting clients offsite more frequently (i.e. at their home or place of business). Since the customer may not enter our branch, how do we meet signage requirements for Regs such as Fair Housing, CRA, CIP, and Truth in Lending?
04/25/2011
During one of our recent exams, it was suggested by the examiners that we open accounts online (which surprised us); they would like us to phase out our brokered deposits and felt we could replace these deposits by opening accounts online. I have been trying to gather some information on what is involved in opening accounts online, in particular the risks involved; how to handle CIP, how to handle disclosures and how to obtain the initial deposit. I put out a question on Banker Threads, but did not receive much information. Can you direct me to any information that would help?Also, our president would like me to do a comparison to Free Checking - the pros and cons vs online accounts. While I have not experienced opening accounts online, I have been at a bank (some years ago) that offered free checking and we had a good experience. Few losses, customers really liked not having to worry about a maintenance fee, and the average balance tended to be around $3,000. I was wondering if you could direct me to any other sources that might be able to provide information or statistics on free checking?