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#2129821 - 05/10/17 12:52 PM Safe Deposit Box-CIP Question
mdog76 Offline
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Joined: Jan 2007
Posts: 645
Would being an owner on a Safe Deposit Box constitute a "Continuous Banking Relationship" and therefore that customer could be considered grandfathered from CIP if they were added to the box prior to 10/1/2003?

Thank you

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#2129823 - 05/10/17 12:57 PM Re: Safe Deposit Box-CIP Question mdog76
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 80,390
Galveston, TX
Yes, but to open a new account after 10/03, you would have to verify that you previously had gathered the required information under the existing customer exemption.

Sec. 1020.100 Definitions.

Refer to §1010.100 of this Chapter for general definitions not noted herein. To the extent there is a differing definition in §1010.100 of this Chapter, the definition in this Section is what applies to Part 1020. Unless otherwise indicated, for purposes of this Part:

(a) Account. For purposes of §1020.220:

(1) Account means a formal banking relationship established to provide or engage in services, dealings, or other financial transactions including a deposit account, a transaction or asset account, a credit account, or other extension of credit. Account also includes a relationship established to provide a safety deposit box or other safekeeping services, or cash management, custodian, and trust services.
Last edited by rlcarey; 05/10/17 01:00 PM.
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#2129835 - 05/10/17 01:51 PM Re: Safe Deposit Box-CIP Question mdog76
Daisy Doodle Offline
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Joined: Feb 2014
Posts: 1,030
Southern U.S.
We require a deposit account to debit for safe deposit box fees, therefore we have no safe deposit boxes without deposit relationships.

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#2130008 - 05/10/17 10:01 PM Re: Safe Deposit Box-CIP Question mdog76
RockChucker, CAMS Offline
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Joined: Jul 2013
Posts: 1,691
The Country
^^^^^ I have been pushing for this since I was hired by this bank. ^^^^^
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#2130011 - 05/10/17 10:11 PM Re: Safe Deposit Box-CIP Question mdog76
Daisy Doodle Offline
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Joined: Feb 2014
Posts: 1,030
Southern U.S.
We take the position that it is suspicious to have a box at a bank isolated from your other banking relationships. I don't know what they are hiding or from whom, but we don't want to play.

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#2130046 - 05/11/17 01:08 PM Re: Safe Deposit Box-CIP Question mdog76
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Quote:
"Continuous Banking Relationship"


You are apparently quoting your policy, not the regulation. We don't know what that means.
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