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#1771998 - 01/03/13 04:52 PM Credit Union/ CIP
parr04 Offline
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Posts: 377
oklahoma
Would a federally chartered credit union be exempt from CIP requirements?

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#1772016 - 01/03/13 05:07 PM Re: Credit Union/ CIP parr04
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
No. The CIP requirements state:

"(a) Customer Identification Program: minimum requirements (1) In general. A bank must implement a written Customer Identification Program (CIP) appropriate for its size and type of business that, at a minimum, includes each of the requirements of paragraphs (a)(1) through (5) of this section. If a bank is required to have an anti-money laundering compliance program under the regulations implementing 31 U.S.C. 5318(h), 12 U.S.C. 1818(s), or 12 U.S.C. 1786(q)(1), then the CIP must be a part of the anti-money laundering compliance program. Until such time as credit unions, private banks, and trust companies without a Federal functional regulator are subject to such a program, their CIPs must be approved by their boards of directors."

The definition of bank includes credit unions and as you can see they are specifically mentioned in the CIP rules.
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#1772034 - 01/03/13 05:34 PM Re: Credit Union/ CIP parr04
kw004h Offline
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Joined: Nov 2009
Posts: 219
Chicagoland, IL
TooTall, were you asking whether a federally chartered credit union would be exempt from the definition of "customer" under CIP?

(3)(i) Customer means:
(A) A person that opens a new account; and
(B) An individual who opens a new account for:
(1) An individual who lacks legal capacity, such as a minor; or
(2) An entity that is not a legal person, such as a civic club.

(ii) Customer does not include:
(A) A financial institution regulated by a Federal functional regulator or a bank regulated by a state bank regulator;


Last edited by kw004h; 01/03/13 05:34 PM.
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#1772037 - 01/03/13 05:37 PM Re: Credit Union/ CIP parr04
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Aha! That would be another way to read that question. I agree that, as a customer, a federally regulated CU is not subject to CIP.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1772057 - 01/03/13 06:02 PM Re: Credit Union/ CIP Kathleen O. Blanchard
parr04 Offline
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Joined: Aug 2004
Posts: 377
oklahoma
Sorry,the question should have asked if a Federally Charted Credit Union, as a customer, would be exempt from CIP requirements.

You gave me the answer I was looking for. Thanks!!

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#1772375 - 01/04/13 01:25 PM Re: Credit Union/ CIP parr04
John Burnett Offline
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John Burnett
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Cape Cod
Caveat -- The regulation itself says the CU is not a customer for purposes of the rule. If the bank's CIP, however, doesn't recognize the exception (by reference to the regulatory definition or directly), you'd have to apply the bank's CIP procedures.
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