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#2094420 - 08/20/16 12:35 AM CIP Online Banking Individuals - View Only
DNana Offline
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DNana
Joined: Nov 2010
Posts: 41
TN
Would a Bank require business online banking individuals with "view only" capabilities to follow the same CIP requirements as the owners of the account?
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#2094421 - 08/20/16 02:16 AM Re: CIP Online Banking Individuals - View Only DNana
rlcarey Online
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rlcarey
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Posts: 77,243
Galveston, TX
That is a contractual issue that should be address in your business online banking agreement. How do they get access?? Is it granted by the bank or does the business grant access??
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#2094434 - 08/21/16 10:32 AM Re: CIP Online Banking Individuals - View Only DNana
Elwood P. Dowd Offline
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Next to Harvey
You need to sort out your fact situation a little bit... The signatories on an entity's business account are generally not described as "owners," they are just signatories. The CIP regulation doesn't apply to them, but your bank's board adopted program may say they are to be identified anyway.

The same analysis applies even more so to a mere "viewer." The CIP regulation does not apply, but their identification may be required by your policy. (The banking rationale for doing so would be pretty weak.)
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#2095083 - 08/24/16 07:45 PM Re: CIP Online Banking Individuals - View Only Elwood P. Dowd
DNana Offline
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DNana
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TN
You are correct, our Bank’s CIP policy does apply to account owners and signers. I’ve inherited the policy and have for the most part been very cautious of making revisions to a policy that has received good comments in examinations and audits, unless regulatory revisions are required.

However this appears to be a time where changes are needed. So the questions arise when anticipating the revisions, should I revise to exclude for online View only authorities, or everyone, since the regulation doesn't apply anyway. I haven’t received many comments regarding CIP and online banking authorities, perhaps banks are complying with the regulation as it states.
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#2095262 - 08/25/16 03:41 PM Re: CIP Online Banking Individuals - View Only DNana
ItNeverEnds CRCM Offline
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The first thing I did when I came to my current bank was revise the BSA policy because it included everyone under the sun. Make the change before you get yourself in trouble by not following your policy and the examiners find some other catch with signers, guarantors, etc.
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