Wading through the definitions in CIP, a customer is a person and a U.S. person includes:
A person other than an individual (such as a corporation, partnership, or trust), that is established or organized under the laws of a State or the United States.
I'm aware that the regulation states: "Additional verification for certain customers. This verification method applies only when the bank cannot verify the customerís true identity using the verification methods described in paragraphs (b)(2)(ii)(A) and (B) of this section."
In researching opinions on what a bank should obtain from a trust (from a legal perspective), there appears to be a split among opinions on whether the bank should obtain copies of any of the pages of the trust documents. If a bank chooses not to obtain copies, could the bank's CIP be written that we would obtain the name, EIN and physical address of the trust, but verification of identity would be performed on the individuals opening the account?
Or would we be deemed to have missed the mark on verification since a trust is included in the list of "customer" and in reality the trust does have documents we just may not want to obtain them.
Thanks in advance for any input.