Does the beneficial ownership rule apply to DBA's (fictitious name registered with the Secretary of State)?
My inquiry has to do with CIP requirements regarding opening an account under a FLUTMA (we are in Florida). The account holder which is the grandmother opened an account under a FLUTMA for the grandchild. The parents do not wish to release a copy of their child's birth certificate due to possible fears of compromise. Is it mandatory to require CIP information on the minor once the Chex Systems clearance has been obtained; is a birth certificate actually required?
I have asked a new customer to provide the business partnership agreement as part of my new account required documentation in order to open a business account. However, the customer is adamant that under partnership law, the general partner has the authority to direct its affairs. We can confirm both entities were organized in Texas on the Secretary of State's website. The customer says that should be sufficient for our requirement. Where can I confirm that it is not required to obtain?
During a recent FDIC exam I was asked for the proof that I am doing some kind of due diligence on the loans that we are purchasing a share of through participations. I happen to have sent a compliance warranty last year, because I had heard some chatter on this. My question is, 1. does it state this requirement anywhere in regulation 2. Does this have to be re-certified annually? 3. Can an acknowledged statement on the loan documents signed by an officer of the other bank take the place of a formal letter?
Are there any laws to protect a customer that has been a victim of domestic violence to keep their physical address confidential and not provide it to the bank due to fear of abuser finding her? How would this affect CIP?
With the new CDD Regulations, will we need to verify signers and CIP on participant loans? Also - Is there a specific way to verify the information for CDD with the shareholders of a company?
Do we have to get two types of identification for CIP?
Can we download business documents from the Secretary of State to open an account?
A person opens a DDA, is properly CIPd, and his name includes "Jr." as a suffix. Later, the same person, same SSN, borrows money without using the "Jr." suffix. Should the lender require the borrower to re-sign the promissory note using Jr. in the borrower's name?