Hello,

We just attended a training lately and I am wondering about a few things that they told us.

1. Do we have to capture beneficial ownership on a business that has a CD that automatically renews? We were told we did in the training.

2. We were told that we had to do credit checks on beneficial owners?

3. We were told that we do not have to have new signage to replace our current CIP signage? We received something in the mail stating mandatory new signage, but it might be a company using the word "mandatory" to sell their product.

Any guidance is appreciated.

Thank you,

Nevermind on the CD Renewals. I just read a previous thread.

#3 - you do NOT have to have new signs. CIP is mandated by the USA PATRIOT Act and the wording is specific to that. This is not the same as the CDD changes and there is no mandatory disclosure or language for it.

Answer to #2: You must obtain consent in order to pull credit on a beneficial owner. You would not be in compliance with FCRA unless you obtain authorization for the credit pull.

See this thread for a discussion on non-documentary methods of verification; https://www.bankersonline.com/forum/ubbt...c-verification.

Thank you both!

Regarding Q1, this was covered in FinCEN's recently issued FAQs. If you haven't read it, I highly recommend that you do.