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#2130014 - 05/10/17 11:34 PM CIP-Law Enforcement Agents
AgentSmith Offline
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Joined: Dec 2015
Posts: 38
Hello All,

I have multiple law enforcement agents telling our bankers that they are not required to give the bank their physical residential address at account opening. Law enforcement contends that they are exempt from the requirement because providing their address to anyone is high risk.

Does anyone have a reason why all law enforcement would be exempted from this portion of CIP? Does anyone allow law enforcement to do this at their bank?

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#2130015 - 05/11/17 12:30 AM Re: CIP-Law Enforcement Agents AgentSmith
rlcarey Offline
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Galveston, TX
Since they are law enforcement agents, they should be able to quote you chapter and verse on the law that allows the exemption.
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#2130016 - 05/11/17 12:33 AM Re: CIP-Law Enforcement Agents AgentSmith
Elwood P. Dowd Offline
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As suggested, you are chasing someone else's rabbit...let the person who cites the existence of authority provide the authority they describe.

There is none.

There are limited exemptions for ID for LEA personnel buying official checks with cash they have confiscated. That has nothing to do with CIP.
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#2130021 - 05/11/17 10:18 AM Re: CIP-Law Enforcement Agents AgentSmith
edAudit Offline
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edAudit
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Posts: 4,773
You are here
I have multiple law enforcement agents telling our bankers that they are not required to give the bank their physical residential address at account opening.

Sorry but it appears that you have multiple potential customers that will not be opening an account.

No discussion no exemption
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#2130098 - 05/11/17 03:50 PM Re: CIP-Law Enforcement Agents AgentSmith
RockChucker, CAMS Offline
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Posts: 1,644
The Country
I guess parking a patrol car in your driveway isn't advertising to others that a law enforcement agent lives there....

Where do they come up with these ideas?
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#2130119 - 05/11/17 05:05 PM Re: CIP-Law Enforcement Agents AgentSmith
MollyM Offline
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Posts: 112
Mississippi
Invite them to seek financial services elsewhere - end of story. Ditto what RockChucker said ---- the car gives them away to begin with LOL
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#2130192 - 05/11/17 08:18 PM Re: CIP-Law Enforcement Agents AgentSmith
Midwest BSA Offline
Member
Joined: Sep 2014
Posts: 54
I BELIEVE they're getting confused and trying to lump it in with this: http://codes.ohio.gov/orc/4501.271

Most states have similar legislation. Vital for officer safety due to sunshine laws, but not applicable here because of customer confidentiality.

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#2130194 - 05/11/17 08:20 PM Re: CIP-Law Enforcement Agents Midwest BSA
Elwood P. Dowd Offline
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Next to Harvey
Thank you. You are probably right about this serving as the basis for the misunderstanding. I was just attributing it to "the cowboy way..."
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#2130358 - 05/12/17 07:59 PM Re: CIP-Law Enforcement Agents AgentSmith
John Burnett Offline
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John Burnett
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Cape Cod
Go back to your bank's CIP. What does it require for address? The regulation requires either a residential or business street address. If your bank carried that latitude into its CIP, these LEAs could legitimately provide you with their business addresses for CIP.
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#2130404 - 05/14/17 01:09 PM Re: CIP-Law Enforcement Agents John Burnett
Elwood P. Dowd Offline
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Begrudgingly accepting the legality, I'll directly question the wisdom of any bank's allowing LEA personnel (or anyone else) to provide anything other than a residential address that can be verified by reviewing their personal identification. Banks send overdraft notices to, file SARs on, and repossess cars of LEA personnel - they are no different than any other customer in terms of the bank's business need for an address.

The world knows the President lives at 1600 Pennsylvania Avenue. I don't see a problem with the bank knowing where Barney Fife lives.
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