I do not understand why our bank requires the customer to sign our CIP form. It has a place for signature for employee filling out the form but not for the customer. Thoughts?

Thoughts? Don't know either.

The bank requires the customer to certify the CIP information? But it doesn't have a place for them to sign? I'm confused.

Sorry, the form i want to use does not have a place for the customer to sign, only the employee. The LOS produces this CIP form automatically from the data we enter into it.

The "bank's" form that is currently being used has a place for both to sign. So i am thinking about discontinuing the bank's if we don't need the signature of the customer because this form is filled out manually. It is not included in the forms that auto populate within the LOS. Very inefficient.

First you need to find out why there is a need for an employees signature as there is no reg. that states you need it and then why you have a need for a customer signature. Was is audit (because the info was not correct during a review???) or a misguided examiner (a good chance) or someone who just thought it was a good idea with a SR in front of title. None of us here will have any idea why.

Like edAudit stated there is no regulation that says the customer or the employee need to sign anything regarding the CIP process.

If for some reason the bank wanted to be able to identify who was completing the form to help with training then I could see where that might be helpful but not required.

Of course down the road when we get into beneficial ownership there could be a spot for the customer to sign to certify the ownership of a given account

Yes, the CDD rule will require that the entity customer's representative provide the information on the ownership of the entity and certify to its accuracy.

The use of the CIP form is related to loan closing. I do not anticipate anyone signing on behalf of the borrower as we do not allow for an attorney in fact to borrow on their behalf. Safe to say employee and customer signature is just something they have been requiring even though it is not required and should not be for CDD if i understand correctly.