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.

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.