I was hoping folks would be willing to share how "deep" you go with CIP on your LLC customers. We're looking at revising how we handle LLCs due to their complexity.

Beyond completing CIP on the LLC the company itself, do you CIP all the members, even if there's a manager? Do you only CIP signers? Or perhaps CIP based on ownership percentage? If you CIP members, who are also LLCs or Corps or Trusts, do you then go further?

I know this is way beyond what's required in the regulation, so I'm really just looking for what banks are doing.

Thanks!

CIP on the company itself.

We perform due diligence on any person with 25% or more ownership of any entity, including LLCs. "Due Diligence" includes most (but not all) CIP info.

We CIP the company, and not the members, unless it is a single-member LLC, and then we CIP the one member.

Thanks for the information. Right now, our process is similar to BrendaC's but at a slightly lower % ownership. We're thinking about bumping the ownership % up.

Like most things in BSA, the decision on "how far to go" with CIP is risk based. Some banks in high risk areas dig down through the many layers of ownership in LLCs, limited partnership, corporate ownership to get to the "real people" behind the deal.

Same here!!