we are going to roll out a business credit card.
we use a outside servicer who also issues the card with our name, but the cards will show up on our balance sheet and we run the risk of loss.
So Corp A buys our product and wants the card to go to a 100 employees. each card will bear the name of the business and the name of the employee.

CIP = do we get the drivers licenses ont these employees. i think the corporation and not these employees, are our customer. But the employees name does appear on the card underneth the employers name.
Our policy says we will do CIP on all customers.

anyone have this type of situation

What does your CIP policy say about whether or not you CIP authorized signers on business accounts? If you do CIP them than I would consider holders of a credit card also subject to CIP.

This is significant enough that I'd consider asking that the CIP program be amended to exclude these individuals. Unless they are liable on the cards (I can't imagine that would be the case) they aren't customers in the regulatory sense, and I question whether you have any reason to need their ID data.

assume we can amend the CIP to exclude these people.... what do you think about OFAC on the employee cardholders? of course we will check with the servicer to see if they are checking OFAC... but if they aren't checking i would assume we would have to check.

We do not CIP our businesses account signers, but we do OFAC check them.

ok, CIP maybe not, OFAC someone needs to check,
and 314a - i assume we need to make sure we check our business card holders (the employees) against 314a too.

Article on business funded prepaid cards begins on page 47.

Hey Ken,

Do you think many of the same concepts in that article apply to business credit cards also? The article is directly about prepaid cards, while the topic question was related to credit cards.