On what basis do you form a "reasonable basis" when deciding to perform CIP on existing customers? At our institution, we have a number of certificate of deposit customers that are jointly owned by an elderly parent and their children. When these parents come in to renew their CD, is it necessary to ID the children, who live out of state, even though they are existing customers? What are other Banks doing to identify out of state customers?

If they are renewing an existing CD, CIP is not necessary, provided your risk assessment and procedures allow this exemption.

However, I too am interested in knowing how others are handling the following situation: elderly customer wants to open a CD with an out-of-state adult child as a co-owner. The elderly customer doesn't always know all 4 minimum ID pieces for the adult child.

A previous thread stated options as: (1) get notarized document from adult child; (2) title account individually until adult child's ID info is received; and (3) persuade the elderly customer to title the account as an ITF, removing account ownership from the adult child during the life of the elderly customer.

Thoughts? Other options?

WE use a signature card with our CDs; so we have the customer (in our office) sign the card and provide his/her ID, etc.; then we have that person send the card to the other account owners to obtain the required ID, etc. with the stipulation that they must get their signature on the card notarized and must still provide copies of the ID required per our policy (at least one piece from our primary category and one piece can come from our secondary category. We also specify a time frame within which all the documentation must be returned to us.

What do you do when a state does not permit its license to be photocopied?

What state are you referring to?

I didn't mean to refer to any state. I know that some banks are requesting a copy of the driver's license for customers that are not present. I'm asking if if is permissible to ask for a copy if the state they reside in does not permit the copying of licenses.

My reason for asking is that there are very few states (only 1 that I know of) that prohibit copying DL's. IOW, this is more of a fear then reality.