Our bank is considering the following change to our CIP process:

The Bank recognizes that there may be instances in which complete CIP information may not be collected on all deposit account owners or signers at the time of account opening; in such a case, the Bank will allow the account to be opened so long as complete CIP information is collected and verified for the primary account owner. However, if the required CIP information is not received for the additional owners/signers within 30 days, designated deposit staff will initiate follow-up processes and remove the owner/signer from the account if completed information is not received within 60 days of account opening. Documented exceptions to this timing requirement may be made by Deposit Operations Management on a case-by-case basis for extenuating circumstances, however, in no event shall a new customer with incomplete CIP information remain on an account for 2 weeks beyond the initial 60 day deadline.

Does anyone see any issues with this? Is it an absolute requirement that we obtain full CIP on ALL account owners prior to opening an account?

http://www.ffiec.gov/bsa_aml_infobase/documents/BSA_AML_Man_2010.pdf

I hope this link works. You need to collect the info on each customer before you open the account.

You can differentiate between legal requirement (name address dob tax id) and additional information the bank wants, as well as full validation to the standards set in your program.

You MUST have the name address dob and tax id at time of account opening.

It would probably require far less effort if you did not "add" signers or owners with incomplete CIP information to accounts in the first place. Why not just insist that new signers or owners will be added only after complete CIP information is obtained?

The four elements of required information (per regulation) for CIP are certainly not so onerous that you should have to wait at all for them. My vote is that without the CIP info you don't add the owner. Note that I am not commenting on whether or not you need CIP on authorized signers. That's a bank policy determination.

Your responses appear to be trending negative and mine won't reverse that flow. The emphasis on identifying the "primary" owner is misplaced. Legally that term has no meaning whatsoever. Operationally, it simply means the first person listed in the account title. If the account title is "Ken or John" your CIP should place exactly the same amount of emphasis on obtaining and verifying the critical information on both customers.

You must obtain the four pieces of identifying information on all customers prior to opening the account. You must verify the customer's identify using documentary or nondocumentary methods or a combination thereof within a reasonable time after opening the account. (As John suggests, only common sense, not the law, would require you to apply that same analysis to a "mere signatory.")


Any lesser process could and should be treated as a violation of law.