Currently, we require Partnership Agreements on new business accts when applicable. Our Policy does not allow for exceptions.

Is there any ruling against making an exception if a potential customer finds it too intrusive? (Btw, we didn't have a chance to

present the Beneficial Owners form before he stormed out. My guess is he would've refused and then we would've refused).

Please share your procedure.

Thanks.

This little snippet from the CIP Section of the exam manual may dissuade you a bit.

Evaluate the level of CIP exceptions to determine whether the bank is effectively implementing its CIP. A bank’s policy may not allow staff to make or approve CIP exceptions. However, a bank may exclude isolated, nonsystemic errors (such as an insignificant number of data entry errors) from CIP requirements without compromising the effectiveness of its CIP (31 CFR 1020.220(a)(1)).

We have in our policy the ability for me (BSA Officer) to make a CIP exception. But I rarely get a request that I think warrants an exception, and I sure wouldn't make one here.

Per Brian's post, an "exception" means the board can be overridden. That doesn't qualify as a "plan" in any circumstance.

Thank you so much.

It helps to understand why you request the document, and what you want it to accomplish. When you open an account for an entity, you're looking to establish two things:
-The existence and identity of the entity (CIP)- this can be accomplished by reviewing documents (such as a partnership agreement, among others) or non-documentary searches (such as a review of Secretary of State filings). Your CIP policy should address which documents and which non-documentary verifications you need to use in each circumstance, and when alternate forms of verification are acceptable.
-The authority of the individual(s) seeking to act on behalf of the entity- this will almost always come from a review of the documents. Without seeing the partnership agreement, do you have another means of ensuring you are accepting the request from the correct person, or the correct number of people? Regardless of how you meet your CIP requirement, assessing the authority of the individuals is sound due diligence, and should never be optional. If the partnership agreement is your only source of this information, you need to review it.

Thank you. Very helpful.