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#1123516 - 02/05/09 03:30 PM CIP on signers
ComplyOhMy Offline
Platinum Poster
Joined: Dec 2005
Posts: 514
Lexington, Kentucky
Don't we have to obtain CIP information from signers, guarantors, etc.?

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BSA/AML/CIP/OFAC Forum
#1123593 - 02/05/09 04:01 PM Re: CIP on signers ComplyOhMy
Ted Dreyer Offline
Diamond Poster
Ted Dreyer
Joined: Apr 2001
Posts: 2,245
You do if your CIP policy requires it, but it isn't generally required by the regulation. There is a section of the regulation that does say: "The CIP must address situations where, based on the bank's risk assessment of a new account opened by a customer that is not an individual, the bank will obtain information about individuals with authority or control over such account, including signatories, in order to verify the customer's identity. 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."

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#1123639 - 02/05/09 04:17 PM Re: CIP on signers Ted Dreyer
Dallas Fan Offline
100 Club
Joined: Feb 2008
Posts: 219
RIC
Although the Reg does not require it, I always advise the staff to get as much information as possible on signers. That way when you have a signer deposit/withdrawal CASH over 10K you have the info you need to file a CTR. I also think that the more info you have on the signers, the better protected your customer is.

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#1123712 - 02/05/09 04:43 PM Re: CIP on signers Dallas Fan
BrendaC Offline
Power Poster
BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
We need to balance CIP with customer due diligence (aka KYC) and prudent underwriting procedures. I would question any underwriting process that did not obtain basic identifying info on loan guarantors. And, in my prior life, we were identifying account signatories long before CIP rules came along for fraud prevention.
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#1124171 - 02/05/09 09:11 PM Re: CIP on signers BrendaC
ahanna Offline
Gold Star
Joined: Aug 2008
Posts: 380
Texas
We always CIP loan guarantors. However, we recently relaxed our CIP procedures for authorized signers on some accounts in order to be more competitive in our market. For example, charitable associations and clubs (such as the local YMCA, booster clubs, etc.)who frequently change signers can now do so by supplying only the signer's name, SSN and signature.

The business is the owner of the funds in the account and they are responsible for anyone they include as an authorized signer. We do reserve the right to require additional documentation/verification for any signer at any time deemed necessary by us.
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