Are we required to collect CIP information if we are participating a loan with another bank that has collected the information?

Your policy should address this.

Ours didn't and we had the following audit comment:

The Bank’s CIP Policy does not yet specify when the Bank will rely on the performance of another financial institution for any part of their customer identification program, even though the Bank participates in loan syndications.

The purchase of an asset does not trigger CIP.

We have some recent participation loans where we are not the lead bank. We have set each of these loans up in our core system as customers. I understood that CIP would be required, but if they are just assets, as you mentioned above, would we note that in our system, as to not generate CIP exceptions for the missing information, or should we still require the lead bank to provide it to us? Thanks

If you merely purchased an existing loan, rlcarey is correct, CIP does not apply. (It doesn't make any difference if the seller is another bank or whether the lender did or did not apply CIP.)

The audit comment to Califgirl is simply a red herring. If the bank buys loans, CIP does not apply. If the bank allows another bank to perform CIP on its behalf then it very obviously is not buying the loan, it's making it and CIP applies.

If you participated in the underwriting of the loan and made your own underwriting decision then you are not purchasing the loan, you are funding it. CIP applies.

I want to make sure I understand Ken's comments. If a loan is made by another institution, and we come along after the fact and purchase part or all of the loan, CIP does not apply because of the purchased assets exemption. However, if another institution has a loan in the works and we get involved with the underwriting before the loan is made, CIP does apply when we purchase part or all of the loan?