My guess is this may be matter of bank policy. But do most banks CIP an individual named deputy on a safe deposit box?

Second, does the deputy sign the box contract in any place or is he/she simply appointed by a box owner and only his/her name would be listed (not signed) on the box contract?

You should have a separate or integrated form for the specific appointment of deputies. Capturing a sample signature of the deputy is always a good idea for comparison purposes when they access the box.

So CIP is not required on a deputy? But it would be a good idea to obtain a signature from the deputy?

Our deputy appointment is included as a separate section on our box contracts. But the section is only signed by the lessee (not the deputy). So where do you suggest we ask for the deputy's signature?

A deputy does not own the box, they only have access to the box.

Basic identification should be conducted to ensure you "know" this individual sufficiently for OFAC verification (legal name) and fraud protection measures. Do you really want someone entering your vault area and placing/removing unknown items from a safe deposit if you don't know who he/she is?

Whether it rises to the level of CIP is up to the bank. IMHO it should come pretty close if not mirror CIP procedures/processes.

Thanks Brenda. So does your financial institution obtain a copy of the deputy's signature on the contract someplace or not. Our form is not really set up for a deputy signature, but I would think we'd want it someplace. However if we CIP these individual's we'd have it on some of the forms we use to gather that information.