Is a CIP required on a NEW loan customer who is already a custodian on his son's account our bank?
In a training last week it was brought to my attention on the new CTR form that it is requiring the ID collection of an entity. In the past this has never been the case and in the FFIEC manual it specifically refers to individuals. FinCEN has said that there is nothing new to the forms except the collection of the new fields. Not in any webinar or documents that we received from FinCEN said anything about identifying document collection of an entity for a CTR. The only thing I have seen regarding this is actually on the form from the help box in the ID field itself. Is this something we have to collect going forward?
We have a charged off account the officer wants us to re-open. If the account holder does not have any other active accounts with us do we need to do all new paper work on the account? Would we need a new CIP verification?
Our bank has an account that is changing signers. The new signers have never before been customers of ours or signers on any of our existing accounts. The signers hold executive positions for the company for which we hold the account and it is changing signers. The company is publicly traded on the NYSE. Do we need to perform CIP on these new signers?
Attention Deficit Disorder
by Mary Beth Guard
Recently, I was diagnosed with CRADD:
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?