We are opening 1031 Exchange accounts. There is a Qualified Intermediary that is the only authorized person - for the actual owner of the funds, we have to have their SSN/TIN for tax reporting but they do not provide their CIP information since they have no access to the account. Do we really just have to CIP the Qualified Intermediary since they are the one that would be our customer?

Yes, if the intermediary won't be doing the tax reporting, you will need the SSN/TIN for the owner of the funds. But your customer is the intermediary, and the CIP regulations say that is whom you CIP. Unless your bank's CIP expands that requirement to cover the third party in the arrangement, you don't CIP the owner of the funds.

What he said.

You should require a W-9 or its equivalent executed by the owner if the account is interest bearing. Anything else is "bank policy."

Thank you very much