I don't think CIP is an issue either, but there are others. On your books you are showing a loan to Ken, but you are totally reliant on Randy's (the guarantor's) identity as well as his ability to repay. Even if the saftey and soundness examiners never mentioned it before, they could question the underwriting practice. The examiner who is most thoughtful might suggest it would be an excellent way to launder money through sham borrowers.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.