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#1842305 - 08/14/13 12:05 PM Privacy Notice
Tocomply Offline
Platinum Poster
Joined: Nov 2004
Posts: 650
I have a deposit customer with an active account who wants to add a name to the account a year after the account was opened.Must we provide an initial privacy notice to the secondary name that is being added? What is the secondary name being added lives at a different address?

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Deposits and Payments
#1842669 - 08/15/13 03:51 AM Re: Privacy Notice Tocomply
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 79,923
Galveston, TX
You might think you are adding a person, but in reality, you are just opening a joint account with the same account number - give them all disclosures.
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#1842749 - 08/15/13 02:47 PM Re: Privacy Notice Tocomply
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,793
Cape Cod
And don't forget that, unless the new joint owner already has an account with you, this is a CIP trigger.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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