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#1071396 - 10/27/08 06:39 PM Displaying USA Patriot Act Notice
amwood Offline
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Joined: Dec 2000
Posts: 90
San Luis Obispo, CA USA
Help! Where does it say in the regulation where the USA Patriot Act notice needs to be displayed? We realize it must be given before account opening but our bank has it hanging in the foyer of the branch about eight feet up from the floor. We don't feel this is sufficient and would like to order stand up notices but need to plead our case. Thanks for all who have the time to give advice.
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#1071406 - 10/27/08 06:46 PM Re: Displaying USA Patriot Act Notice
Little Miss BSA Offline
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Little Miss BSA
Joined: May 2007
Posts: 1,185
Miami
If not mistaken you will find this topic under the CIP
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#1071423 - 10/27/08 07:09 PM Re: Displaying USA Patriot Act Notice Little Miss BSA
P*Q Offline

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P*Q
Joined: May 2001
Posts: 8,450
Somewhere
Here is the text from the regulation

(5)(i) Customer notice. The CIP must
include procedures for providing bank
customers with adequate notice that
the bank is requesting information to
verify their identities.
(ii) Adequate notice. Notice is adequate
if the bank generally describes
the identification requirements of this
section and provides the notice in a
manner reasonably designed to ensure
that a customer is able to view the notice,
or is otherwise given notice, before
opening an account. For example,
depending upon the manner in which
the account is opened, a bank may post
a notice in the lobby or on its website,
include the notice on its account applications,
or use any other form of written
or oral notice.
(iii) Sample notice. If appropriate, a
bank may use the following sample
language to provide notice to its customers:
IMPORTANT INFORMATION ABOUT PROCEDURES
FOR OPENING A NEW ACCOUNT
To help the government fight the funding
of terrorism and money laundering activities,
Federal law requires all financial institutions
to obtain, verify, and record information
that identifies each person who opens an
account.
What this means for you: When you open
an account, we will ask for your name, address,
date of birth, and other information
that will allow us to identify you. We may
also ask to see your driverís license or other
identifying documents.

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#1071530 - 10/27/08 08:40 PM Re: Displaying USA Patriot Act Notice Little Miss BSA
Lil'Belle Offline
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Lil'Belle
Joined: Dec 2006
Posts: 193
Texas, United States
We have signs at each teller station and also on the corners of the desks of the new accounts department. We also have it on our website.
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#1072472 - 10/29/08 01:35 PM Re: Displaying USA Patriot Act Notice Lil'Belle
Bagweaver Offline
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Joined: Nov 2005
Posts: 2,409
SW GA
If accounts are only opened face-to-face in a branch, is there a need to post the notice on the web site?
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#1072920 - 10/29/08 06:33 PM Re: Displaying USA Patriot Act Notice Bagweaver
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
No. If you are not opening accounts online or gathering information from customers to open accounts online, you do not have to post your CIP notice on your site.

Our procedures need to ensure that the customer is provided the notice (posted notice on CSR desk, paper notice on new account form, or oral) before we open the account.
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#1073255 - 10/30/08 12:13 PM Re: Displaying USA Patriot Act Notice BrendaC
Bagweaver Offline
Diamond Poster
Joined: Nov 2005
Posts: 2,409
SW GA
That's what I thought, but I wanted to make sure.

Thanks
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#1079222 - 11/07/08 09:03 PM Re: Displaying USA Patriot Act Notice P*Q
Rocky P Online
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Joined: Jun 2003
Posts: 7,356
Florida
PQ, what is the cite for the notice requirement?

Also, we're opening National CD's (only federally insured banks - rates are provided through the internet, the rest of the transaction is fax and mail) - the customer never comes near the bank. Is the notice required under those circumstances?

Thanks
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#1079228 - 11/07/08 09:08 PM Re: Displaying USA Patriot Act Notice Rocky P
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
I would recommend adding the CIP notice at the top of the application or new account form completed by the customer.
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#1079229 - 11/07/08 09:09 PM Re: Displaying USA Patriot Act Notice Rocky P
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,557
Cape Cod
31 CFR Part 103, section 103.121(b)(5).

http://www.bankersonline.com/regs/103/103-121.html

The notice is required to be given in one form or another before opening any new account relationship. It's one of the mandatory CIP steps.
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BankersOnline.com
Fighting for Compliance since 1976
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#1079297 - 11/07/08 09:55 PM Re: Displaying USA Patriot Act Notice John Burnett
Rocky P Online
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Joined: Jun 2003
Posts: 7,356
Florida
Thank you for the cite -

John, as a point of clarification, since the accounts we open over the internet are federally insured financial institutions, then they would be excluded from the notice because:
ii) Customer does not include:
(A) A financial institution regulated by a Federal functional regulator or a bank regulated by a state bank regulator;

Is that correct? (Please say yes!)
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Integrity. With it, nothing else matters. Without it, nothing else matters.

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#1079381 - 11/08/08 05:12 PM Re: Displaying USA Patriot Act Notice Rocky P
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,557
Cape Cod
If your customer is an FI, yes.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1082144 - 11/14/08 05:59 PM Re: Displaying USA Patriot Act Notice John Burnett
Queen Mum Offline
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Queen Mum
Joined: Mar 2001
Posts: 3,920
OK
There are a couple of different signs in the Bankers Tools area that you can use.

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