Maybe I'm not seeing it, or maybe I'm thinking too much about this, but does CIP regs state that identification must be done at application?
According to Kirchaman, an "account" for CIP purposes is an ongoing, formal banking relationship, such as a deposit account, a loan or line of credit, a safe deposit box lease, trust services, and the like.
Is there an ongoing banking relationship at application or does the relationship start when the loan is originated?
I'm asking because our mortgage company would rather get verification at closing (this would be up to the title company that closes our loans). The L.O. would get social security number, address and date of birth. It would go through processing and a credit report would be obtained.
If only one applicant is there with the L.O. and they have to send disclosures home for the other applicant to sign, when would they get identification from the person not there?
_________________________
blah