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#2127355 - 04/20/17 07:43 PM Municipalities and CIP
Calmeida12 Offline
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Joined: Sep 2012
Posts: 249
What kind of documents for CIP purposes does anyone collect at account opening for Municipalities and their authorized signers? Thank you.

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#2127360 - 04/20/17 07:54 PM Re: Municipalities and CIP Calmeida12
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,336
Cape Cod
Does your bank's Customer Information Program require you to obtain such information for municipal accounts? It's not required by the regulation (although you clearly need to verify the authority of purported authorized signers).
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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#2127364 - 04/20/17 07:59 PM Re: Municipalities and CIP Calmeida12
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Read first See Prior Thread

Unless your bank's board approved CIP decided to include municipalities under the definition of "customer", then you do not need to conduct the formal CIP. Having said that, you should ensure that you are dealing with authorized representatives of an actual municipality, and you have some way to verify that person should they wish to come in and conduct transactions on the account - in other words - use the same common sense that you normally would when opening a business account. But you do not need to worry about your CIP documentation/verification and record retention.
Regulations are a poor substitute for ethics.
Just sayin'

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