Our CIP policy requires authorized signers to follow CIP requirements. We have a business customer who is large privately-held company and are opening an account at our bank. The company's H/R dept will not release the SSN of the authorized signers without consent.....that's kewl.

Their comment was one of the last several banks they had accounts accepted the signer's last 4 digits of the SSN. This is a first for our bank so my question is - Will this comply with the CIP requirement of providing the SSN?

The requirement for an authorized signer's SSN comes from your policy, not the regulation. Change your policy and it's fine, but I'm not certain what value the last 4 digits would have to you.

Yes, Ken I know the regulation doesn't require authorized signers to be CIP'd but our bank made that decision before my BSA Officer appointment.

I realized most banks don't require this for obvious reasons. So I would appreciate any feedback for banks who do/do not require authorized signers and why? PLEASE FEEL FREE TO PM with your feedback.

As our bank grows, this our requirement for this will grow to be a PAIN, so now may a good time to re-visit this policy requirement.

THANKS!

Hi, Ann,
I am at a medium sized bank ($350M) & we require CIP info on all authorized signers-including the entire SSN. We feel the need to fully identify all persons permitted access to the account. We create a profile for each signer & that way they are scanned regularly along with our database to make sure they are not on the restricted lists.

I am at a bank with assets of 1.3 Billion and we require full CIP for all signers including POAs on accounts. We do the same as Edie does, a profile is created for each signer and due diligence is performed just as if they are an owner of the account.
If someone does not want to provide the information, we do not add them as a signer.

Same thing here. We are $350M as well.

We CIP and ID all authorized signers. Why would the SSN not be coming from the signer when they are added to the account? i can understand that an HR department wouldn't release the info but the individual should be providing that. Maybe I misread something?