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#2150664 - 10/20/17 06:02 PM CDD/Beneficiary Rule - Customer Notice
ABT Offline
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Joined: Nov 2010
Posts: 32
Does the new CDD/Beneficiary Rule have any customer notice requirement?

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#2150665 - 10/20/17 06:11 PM Re: CDD/Beneficiary Rule - Customer Notice ABT
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,627
Cape Cod
There is nothing like the CIP notice, if that is what you're thinking of. And there is no requirement that you notify existing entity customers about what's coming. There is, however, an explanatory notice at the top of the model form in Appendix A to ยง 1010.230.
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#2150667 - 10/20/17 06:18 PM Re: CDD/Beneficiary Rule - Customer Notice John Burnett
ABT Offline
Junior Member
Joined: Nov 2010
Posts: 32
Yes John, that is what I needed to know if there was a customer notice requirement as there is with CIP. Thank you for your guidance!

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#2150676 - 10/20/17 06:36 PM Re: CDD/Beneficiary Rule - Customer Notice ABT
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,272
Illinois
For others reading this thread, don't be surprised if you receive calls from your forms vendors offering to sell you new signage for all of your branches. Since it's not required, it's up to you whether or not this is considered money well spent.
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#2150748 - 10/21/17 10:05 AM Re: CDD/Beneficiary Rule - Customer Notice BrianC
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
A banker showed me a "homemade" notice, replete with the American flag and eagle in the background, yesterday. If the first paragraph of Appendix A was intelligible, it would suffice. However, the "early adopters" I've spoken with indicate there really isn't that much pushback from customers so I'm not sure what the point might be.

Your most likely source of pushback is your employees. Make a sign for them. wink
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