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#1792613 - 03/07/13 11:18 PM CIP - publically traded entities
sb1 Offline
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Joined: Jan 2006
Posts: 135
It states under the CIP rulings in the FFIEC examination manual that publically traded entities are excluded from the definition of customer under CIP requirements(as described in 31 CFR 103.22(d)(2)(ii)through (iv) - this section refers to CTR exemptions which is confusing

We presently are in the process of completing a loan application for a publically traded entity.Our BSA policy states that we CIP all signers of a business entity even if not owners. Could we exempt the CIP of the signer as I believe we are going to have a hard time collected the neccessary documents on the signer as long as we make a revision to our BSA policy to allow for this exemption?

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#1792615 - 03/07/13 11:25 PM Re: CIP - publically traded entities sb1
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
Revise the policy first - then you should be OK.
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#1792941 - 03/08/13 06:18 PM Re: CIP - publically traded entities sb1
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Ditto, the regulation excluded identification of the entity, but it never required you identify a mere signatory. This is about the wording in your bank's policy, nothing else.
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