09/08/2003
In my state a minor can contract on a bank account and be held responsible for the account. With this in mind would the CIP requirements mandate we obtain proper identification if a minor is a joint owner of an account or can we rely on the identification of the adult on the account?
09/08/2003
How should our CIP handle verification on retail contracts purchased from local retailers?
09/08/2003
I am not seeing eye to eye with my lenders on the subjects of OFAC and customer identification. Please give me some guidance on the necessity of checking OFAC and the process for identifying loan customers under the US PATRIOT Act. I want them to treat loan customers no differently from deposit customers. I want OFAC checked, I want the customer positively identified.
09/08/2003
In regards to the USA PATRIOT Act CIP provisions: For addresses similar to a P.O. box, such as AIM Mail Services, Mailboxes Etc. (now The UPS Store), Pak Mail, Parcel Plus, PostalAnnex, PostNet and others that essentially compete with local post office services (by providing private mailboxes), do banks have any requirement to try to identify these types of addresses? Would we need to request an actual residential address? (In reading the rule and its preamble, these would be considered as business addresses and may constitute compliance. However, these could also be a means for bad people to open an account without providing a true physical address. These companies extend their business street address to customers and assign a box or suite number. The result is an address that cannot be distinguished unless it is listed on a fraud file somewhere.)
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.
09/08/2003
There have been numerous threads regarding CIP policy versus procedures. Some threads state that the CIP procedures need to have Board approval whereas others say a general overview of procedures is needed. My question is 1)do the procedures really need to go to the Board for approval and 2) how in depth do these procedures need to be? Could we keep the policy separate from the procedures or do they really need to be a single document?
09/08/2003
We are a commercial bank with a large number of business accounts. Many of these accounts have numerous signers who are bookkeepers and the like with no authority or control. Are we required to collect the ID of these individual as well as those with authority and control? Or are we permitted to collect the only ID of those who are in authority/control of the company as demostrated on a corporate resolution or similar documentation?
09/08/2003
Prior to the passing of the USA Patriot Act, what was the responsibility of a national bank in verifying the "new account" customer's identification before opening a new account? I know in the USA Patriot Act, Section 326 clearly addresses the current requirements. I am wondering what regulations were in place as of 1/2002.