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#1508047 - 02/10/11 04:26 PM Monetary Instrument Purchase
parr04 Offline
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Joined: Aug 2004
Posts: 383
Would a authorized signer on an account be considered an account holder? I know they are not an account owner but could they be considered an account holder?

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#1508057 - 02/10/11 04:37 PM Re: Monetary Instrument Purchase parr04
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,700
Cape Cod
Your question needs definition. Would they be considered an account holder for what purpose?
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1508198 - 02/10/11 07:07 PM Re: Monetary Instrument Purchase John Burnett
Deena Offline
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Joined: Nov 2000
Posts: 2,701
I'm guessing for the purpose of purchasing monetary instruments when the bank has a policy to only sell them to deposit account holders. That's our policy and we would not sell to an authorized signer.
Opinions expressed are mine and not necessarily those of my employer.

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#1508376 - 02/10/11 09:14 PM Re: Monetary Instrument Purchase Deena
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
We do not consider an authorized signer to be an account holder nor a customer for purposes of MI purchase. Our policy is that we do not sell to non-customers except in limited circumstances. We spell out the limited circumstances, one of them being that we will sell to a signer when the purchase is on behalf of the account owner (think signers on business accounts).

The remitter is always listed as the account holder in these instances. The MI log (when needed on cash purchases) is completed with all the required non-customer information from the actual purchaser (person at the window) with an extra line for "purchased on behalf of (insert customer name and account number)". Just came through a BSA exam, and had no problems with that method.
I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.

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