Do you have to CIP a public unit acct? We have a teacher at a seminar stating that we must.

"Public unit" is not a familiar term to me.

If it means governmental agency, then it is excluded from the definition of "customer" in the CIP regulation; i.e. the regulation does not apply.

Thanks Ken - I figured the seminar speaker was incorrect.

Public Units include government agencies, school districts, cities, counties and parishes, police and fire departments, sewer and water districts, public hospitals, public colleges/universities, and public airports.

Government entities, State and Federally Regulated banks are exempt from the definition of "customers" under the Custmer Identification Program (CFR 103.22).

Here is where you find the term "public unit." http://www.gpo.gov/fdsys/pkg/CFR-2012-title12-vol5/xml/CFR-2012-title12-vol5-sec330-15.xml

The regulation in question is now 31 CFR Part 1020, section 1020.220. However, the key is the definition of customer, found at 31 CFR Part 1020, section 1020.100(c), and that refers to 1020.315(b)(2) through (b)(4) for the exceptions.