Since beneficiaries are not customers as per CIP, do we have to collect a physical address for them or would a PO box address be sufficient? Also, what do the majority of banks collect on beneficiaries of accounts: just name and address or does anyone also collect DOB, SSN? Thank you.

We collect all of the required information on beneficiaries just as if they were customers. This is mostly due to core system limitations. Unfortunately our core system does not separate customers who are only beneficiaries from actual account holding customers. Theoretically in our system someone could bypass CIP by being established as a beneficiary then coming in at a later date and opening an account. Since they already are in our CIF there is a possibility that the individual opening the account could skip the CIP process.

Where possible, it's a good practice to obtain as much identifying information as you can, including an address and, if applicable, mailing address. That can help when the account owner dies, assuming the beneficiary designations haven't changed. It can be easier to contact, and to verify the ID of individuals claiming to be, beneficiaries with this information.

I have no issue with supplying address, social and dob, but
several banks in my area require a copy of a current driver's license for beneficiaries. I won't do it, so I take my business elsewhere.

Does seem a bit overzealous. And it's often likely to get push-back on SSN on a beneficiary if the account owner doesn't know her grandkids' SSNs, for example. I think it's a good practice to get the info when possible. Unless you want to turn business away, you should also build some flexibility into your policy on this question.

As beneficiaries are not "customers," requiring identifying information on them is simply not a BSA issue. It's probably more important on accounts that have income tax consequences; e.g. IRAs and HSA's. If a bank requires address information on beneficiaries that implies it intends to track them down if necessary. I don't think so...

Requiring the DOB is good and also noncommittal. It would allow you to be more comfortable in knowing you were turning over the money to the right person. SSN is better, but, as noted, Grandma may not be willing to ask for it as she does not want to announce her plans for disposing of her property.

Requiring the beneficiary's identification is a very reliable indicia of the fact that the bank really doesn't comprehend why it does certain things, but believes that doing those things more frequently would somehow be good.

We get as much information as possible as a best practice name, address, ssn and DOB. However, the Policy cleary states these are not customers and are not subject to CIP and if the beneficiary is not willing to provide we do not require it. Further, we do not perform any monitoring ensuring the information has been obtained or not.

We do screen beneficiaries for OFAC and having additional information helps to clear any potential matches.