Skip to content
Thread Options
#121796 - 10/10/03 02:19 PM Annual Notice CIP

Section 103.121(b)(6) says that when a banks relies on another FI to obtain and verify ID, it must receive an annual notice of compliance. The other FI must be subject to BSA and must be regulated by a Federal Functional REgulator. Would the FTC (who governs mortgage companies) be a Federal Functional REgulator? I know we'll need the annual notice from banks we participate with, but I'm not sure about loans purchased from brokers.

Return to Top
#121797 - 10/10/03 03:13 PM Re: Annual Notice CIP
Ted Dreyer Offline
Diamond Poster
Ted Dreyer
Joined: Apr 2001
Posts: 2,245
The FTC is not a Federal Functional Regulator. If you look at the definitions for the CIP reg, subsection (a)(4) says that a Federal Functional regulator is defined at 103.120(a)(2). If you look at that provision, it says: "Federal functional regulator means:
(i) The Board of Governors of the Federal Reserve System;
(ii) The Office of the Comptroller of the Currency;
(iii) The Board of Directors of the Federal Deposit Insurance Corporation;
(iv) The Office of Thrift Supervision;
(v) The National Credit Union Administration;
(vi) The Securities and Exchange Commission; or
(vii) The Commodity Futures Trading Commission."

Return to Top

Moderator:  Andy_Z