We have a real estate customer that wants to deposit earnest money into a 60 day C.D.. The C.D. is styled:

John Smith
Real Estate Co. Name

John Smith actually owns the funds (its his earnest money) and we use his SSN for reporting purposes. However, since our customer is actually the real estate company we are not quite sure what type of identification measures are required for CIP. Yes we can have a copy of the DLs sent over, but is this sufficient? Has anyone delt with this?