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#1703090 - 05/24/12 07:07 PM CIP-Corporate Resolutions
mdog76 Offline
Platinum Poster
Joined: Jan 2007
Posts: 645
I hope this is in the correct forum. When/If you are not the lead bank in a participation loan, does the secondary (lack of a better term) bank need to obtain corporate resolutions and CIP information? The customer will not hold any deposit accounts with us.

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#1703092 - 05/24/12 07:11 PM Re: CIP-Corporate Resolutions mdog76
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
If you literally buy the loan; i.e. your institution did not participate in the initial credit decision, then the borrower is not opening an account at your bank and does not meet CIP's definition of a "customer." (Purchased loans are also specifically excluded.) Thus, the regulation does not apply.

The hook is that there is a wealth of examiners who do not comprehend that.

Consider too, verification of the borrower's identity reflects on the value of the credit; it's just a good idea and it would be smart to have evidence that it was done.

Prior thread.

If you would require a resolution for a loan you made directly, I suggest you require a copy of one here. However, the resolution is not a CIP issue.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

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