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#2150493 - 10/19/17 03:52 PM BO Certification Form
JennKK2 Offline
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Joined: Nov 2006
Posts: 250
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I cant seem to find where my question may have been addressed in an earlier post, but there is a question as to when the customer comes to open the account and doesn't have any CIP information with them - can we give them the form to take with them, gather the information, and bring it back with copies and sign the certification form in front of the bank rep.
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#2150509 - 10/19/17 04:29 PM Re: BO Certification Form JennKK2
bcompliance Offline
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Joined: Sep 2014
Posts: 1,238
I don't think anything prohibits that. I'd simply tell the customer to come back with the info and then fill it out at that time and open the account.
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#2150587 - 10/20/17 10:10 AM Re: BO Certification Form JennKK2
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
There is no problem in the person opening the account taking the form and bringing it back. The issue is whether your bank opens the account before you get the information. I simply would not.

Banks are required to obtain the information "at the time of account opening." It would have been helpful, even logical, if the timing requirement had mirrored one of those found in the CIP regulation:
* prior to opening the account or
* within a reasonable time after opening the account.

Since it does not, banks need to set their own timing requirement. Anyone who has ever opened new accounts knows that the only time the bank has any real power to elicit information is prior to account opening. Otherwise, you may be "following up" with the customer for an extended period, trying to extract something you should have required up front.
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