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#120953 - 10/08/03 01:26 AM
Re: denied loans
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10K Club
Joined: Oct 2000
Posts: 27,750
On the Net
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I'm not sure I understand it the way it is worded. But denied and withdrawn applicants are not "customers" so no CIP is required. Existing customers are exempted so long as you have "reasonable belief" you know them.
_________________________
AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#120954 - 10/08/03 02:10 AM
Re: denied loans
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Anonymous
Unregistered
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Andy - our bank has credit scoring for consumer loans. For purposes of CIP, if it is a new loan customer without a previous banking relationship wouldn't you want to verify the ID first before your submit the request for credit scoring? I guess I am a little confused; you said a denied applicant is not a "customer". So that being true, you should get the loan scored first for approval or denial, and then "verify"??? Just want to make sure I understood your comment. Thank you.
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#120956 - 10/09/03 01:18 PM
Re: denied loans
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Anonymous
Unregistered
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I have told our officers to perform CIP at application time or as early in the process as possible. To me this makes sense if you are meeting with the customer in person and using documentary identification.
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#120958 - 10/09/03 05:20 PM
Re: denied loans
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Diamond Poster
Joined: May 2001
Posts: 1,873
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I've been reading these posts and I know that we do not have to CIP customers "seeking" to open an account. Therefore, as Andy stated, if we deny a loan then no CIP is required.....My problem is that the examiner stated that we must retain the CIP information a denied loan.
I would like to point out to him that he is incorrect, however, I can't find the language or similar language in the Rule....Can someone help please?
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Riding the waves of change.....2014
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#120959 - 10/09/03 07:36 PM
Re: denied loans
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Anonymous
Unregistered
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Here is another situation we just ran into. We do not do the CIP on applicants unless they are approved. The loan was approved. Customer comes in to sign papers and bring i.d with them. Customer gets here and has no primary identification (drivers license, etc.). We did not advance the proceeds and told the customer we would not do so until he brought in proper id. What if they don't come back or say they can not provide us with an i.d. What reason do we give for denying the loan on the adverse action notice because the loan was actually approved except for the id problem?
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#120960 - 10/09/03 08:04 PM
Re: denied loans
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Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
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You are required to obtain the 4 pieces of information: name, address, dob and TIN. If you then deny the loan, based upon a credit report, there is no need to "verify" the ID for CIP purposes. Hence, no additional documentary or non-documentary steps would be required. You would however, maintain the 4 pieces of information with your denied loan file.
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