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#1304200 - 12/11/09 10:12 PM Still missing CIP info. - now what?
Anonymous
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We opened a deposit account for an LLC a little over a year ago. To verify the id of the LLC we generally obtain corporate documents from the LLC, the Bank failed to obtain this information at when the account was opened and now over a year later we still don't have any corporate documents for this LLC. We have attempt to contact the individual who opened this account multiple times via email, phone calls, letters, etc. and have gotten nothing in return...what do we need to do now?

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#1304215 - 12/11/09 10:17 PM Re: Still missing CIP info. - now what? Anonymous
YosemiteSamIAm Offline
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Guess
Close the account and send a cashiers check via certified mail with return receipt to the address on record.
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#1304216 - 12/11/09 10:17 PM Re: Still missing CIP info. - now what? Anonymous
David Dickinson Offline
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David Dickinson
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Central City, NE
Close the account.

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#1305687 - 12/14/09 11:50 PM Re: Still missing CIP info. - now what? David Dickinson
DebL Offline
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Joined: Jan 2007
Posts: 314
CA
Close the account and make sure that you have procedures in place to deal with this sort of error in a more timely manner going forward.
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#1305720 - 12/15/09 11:11 AM Re: Still missing CIP info. - now what? DebL
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,293
Keep in mind that banks are required to have procedures for closing accounts for CIP issues as part of the CIP program.
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#1305721 - 12/15/09 11:30 AM Re: Still missing CIP info. - now what? Kathleen O. Blanchard
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Our policy, as an example, gives 30 days for required documentation to be provided, and the Ops Officers in each branch have a Deficiency Log where they keep track of these items.
The logs are reviewed monthly to ensure that items do not go past the 30 days.
A procedure like this may help you.

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#1309242 - 12/18/09 04:22 PM Re: Still missing CIP info. - now what? MagicCity
Fallgirl Offline
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Fallgirl
Joined: Mar 2005
Posts: 432
Wisconsin
How would you handle it if it is a loan customer? Do you call the loan?

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#1309900 - 12/21/09 03:27 AM Re: Still missing CIP info. - now what? Fallgirl
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,765
Central City, NE
Yes.

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#1310249 - 12/21/09 05:17 PM Re: Still missing CIP info. - now what? David Dickinson
John Burnett Offline
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John Burnett
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Posts: 40,086
Cape Cod
If the loan is current, check with counsel before calling it. You may be caught in a Catch 22, with no legal reason to call the note and missing CIP info. Counsel is likely to agree, I think, that inability to document that your borrower legally exists should be reason enough, but check it out with counsel anyhow.

One thing you'd be crazy NOT to do is to dig up the reason the loan was booked and funds advances without completion of your CIP. Then take appropriate prospective action to ensure it doesn't happen again.
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