I haven't seen this issue addressed. If I missed it, pelase point me in the right direction.

We are trying to find a reasonable way to open a joint account when one or more customers is out of state. A typical scenario has "Mom" come in to open an account jointly with an adult child who lives out of state. Under CIP, we will not put "junior" on the account until we get the 4 required pieces of identification. We then planned to send a request to the out-of-state signer asking for verification info (copy of drivers license, etc.) at which time we would also supply the notice. (If we don't get the verification back in a reasonable time we take that signer off the account.)

Our dilemma is that, technically, the notice should be given before we add their name to the account. Can anyone see a way to deal with this issue other than not adding to name until after we have mailed the notice?

I can't answer your question with any authority, but, just wondered if adding the out of stater as a "convenience signer" rather than a co-owner until you obtain the docs for verification would make any difference ? Doesn't this CIP stuff just raise the hair on the back of you neck ? It does to me because I am an over-50 male and that is the only place hair grows on me anyore.

I know this may be a change in practice for your institution, but in high risk areas the it is more usual not to open an account with any name until the verification process has been completed for that individual. This only applies to consumer accounts. They will usually do two signature cards - the first with the opening person's name only (marked temporary for husband/wife) and the second with the other person's information entered. They give the second signature card to the customer with instructions to get it signed and get the second person's identifying information. When the completed paperwork is received they maintenance the account and add the second person, and archive/scan the new signature card.

Otherwise, how do you monitor all the accounts to make sure that you have received all of the required information? Also, if you don't get the information/signature you'll have to remove the person's name from the account - what do you do then? If you don't close the account then you still have the original checks with two people's names floating around out there. If you do close the account then you incur a cost for new checks (if free), or the original customer has to pay.

It's just cleaner to handle it that way.

I don't think we have "convenience signers" in Michigan. You are an account owner or you are not, unless there is a power of attorney or some legal fiduciary capacity involved.

(I am an over-50 female, and the hair I have is turning greyer by the minute. )

I agree that your suggestion is cleaner. Unfortunately, management feels strongly that they want to have the option to continue opening such accounts. We do not allow this for just anyone, usually for existing customers, in what we deem to be low-risk scenarios. We will be able to flag accounts on our software for missing documentation and get regular reports for follow up. We discussed the possibility of having to remove an account owner but management is confident that it will be such a rare occasion that they can live with it.

I guess we will have to see how it works and adjust our policy later if needed.

You may want to check your state's multiple-party account laws. In California, we can't just "remove" a signer who's been added to an account (even if we only meant it as "provisional" until we could verify them). Either the account has to be closed and re-opened under a new number, or all parties have to sign agreeing to the removal. Be careful!

Thanks. I hadn't thought about state law. Our existing contract has a provision for designating an account as provisional until all required information is received, so I am assuming this is okay in Michigan, but I will check more closely.