09/08/2003
Do you know of anyone that sells the CIP notices for the looby area and new accounts? We wanted a professional made poster. We would be interested in purchasing several if someone has them and would like to also see brochures that you have available for the customers to take.
09/08/2003
At our bank we open Escrow Trust Accounts. Our customer is the Escrow Company and they are opening accounts under their client's name and social security number as a trust. We are only obtaining the name and social security number of these individuals. Are we obligated to ask the escrow companies for more information on their clients, such as their address and date of birth and identification?
09/08/2003
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.
09/02/2003
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.
09/01/2003
09/01/2003
Commonly cited violations have long been a source of important information for the design and management of compliance programs.
09/01/2003
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.
08/25/2003
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?
08/18/2003
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?
08/04/2003
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?