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#2175289 - 04/26/18 12:41 AM Beneficial Ownership - "New Account"
TryingtoComply Offline
Diamond Poster
Joined: Apr 2013
Posts: 1,999
The West
Under Question 1 on the definition of "account" in the FAQ on CIP requirements, we read, "when the account is a loan, the account is opened when the bank enters into an enforceable agreement to provide a loan to the customer." (Thank you John Burnett)

When is everyone considering a deposit account opened? When the first deposit is accepted?

We generate signature cards with account numbers that are given to RMs to take out for signatures. We may not get the signed cards back for a few weeks. The opening date on our core system could be weeks different from the date the CBO and signature card is signed. How is everyone addressing this?

This may have been addressed in a different thread, but I can't find it right now.
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TryingToComply
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#2175334 - 04/26/18 03:02 PM Re: Beneficial Ownership - "New Account" TryingtoComply
EB, CAMS Offline
100 Club
EB, CAMS
Joined: Mar 2009
Posts: 133
flyover country
We've instructed our staff not to upload accounts until they have the signed documents in hand. They have the ability to print signature cards ahead of time like you mention. But we are not actually "opening" the account until we have signed signature cards and beneficial owner certifications.
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#2175620 - 04/27/18 04:30 PM Re: Beneficial Ownership - "New Account" TryingtoComply
Susielou Offline
Gold Star
Joined: Aug 2005
Posts: 351
Midwest
We are doing the same as Frog Lady.

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