Had a new customer come to bank the other day. Wanted to open a certificate of deposit for her mother and daddy(Bank knows new customer). Customer father is an assisted living facility and doesn't have an unexpired government issued id. Her Mother also doesn't have an unexpired government issued id. The CD will be in parents name. What can bank use for CIP for this customer?

She can't represent the interests of another individual without having the legal authority to do so. That authority could be in the form of a power of attorney or a court order of conservatorship.

Does you Bank have an exception process for the elderly such as Medicare card?

I would look for a Power of attorney as stated by BrendaC as many in the assisted living would/should have them in place.

I have the following exception in my CIP policy:

• NOTE: Consistent with the provisions outlined in the Bank’s BSA Policy, special consideration may be allowed for certain elderly or disabled persons that may not possess identification documents that would normally be considered acceptable by the Bank. Therefore, and only if no other form of acceptable identification is available, the Bank may accept as appropriate identification, a social security, Medicare, Medicaid or other insurance card, along with another document that contains both the name and address of the individual (e.g.: an organization membership or voter registration card, utility or real estate bill). These documents will be accepted only if the Bank is confident that the elderly or disabled person is who he/she says he/she is.

I forget to add this to my post, but customer does have power of attorney and provided a copy that was filed.

Thanks for help.

If the principals are no longer competent, you CIP the attorney in fact and title the account as a fiduciary relationship. These examples assume you have a POA for both individuals and that she is named as AIF in both.

Examples:
Joe or Mary Smith
By Sally Smith, Attorney in Fact

Sally Smith, Attorney in Fact for
Joe or Mary Smith

Of course it's possible to be in a nursing home yet still legally capable. In such case, you'd have to consider the individuals on whose behalf the account is being opened your customers for CIP purposes, even if there is a power of attorney allowing the daughter to act on their behalf. Then, the account would be set up in the parent or parents' names and daughter will be an authorized signer as AIF.

The father who is in the nursing home is still legally capable and thus the bank is going to title the CD in the parents name. We are going to request other information and update our policy to deal with these types of exceptions.

Thanks for your help.