Skip to content
BOL Conferences
Learn More - Click Here!

New Reply Thread Options
#2198443 - 11/16/18 03:30 PM CIP
Anonymous
Unregistered

Looking for thoughts on grandfathered accounts that did not require the current CIP requirements, but now we have obtained identification from them. Is it required to input the information or just a good practice? I am on the side of inputting the information but am getting a little push back.

Return to Top Reply Quote Quick Reply Quick Quote
#2198485 - 11/16/18 05:36 PM Re: CIP Anonymous
P*Q Offline

Power Poster
P*Q
Joined: May 2001
Posts: 8,458
Somewhere
What does your CIP/BSA policy say? And if you obtain the license why wouldn't you input the info? In case you ever have to file a SAR/CTR? And what's the pushback? Because they have to enter a couple more pieces of info into the system?

Return to Top Reply Quote Quick Reply Quick Quote
#2198491 - 11/16/18 05:49 PM Re: CIP Anonymous
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,662
Originally Posted By Anonymous
Is it required to input the information or just a good practice?

It would only be "required" if you had not previously formed a reasonable belief you knew their true identity or if you policy requires it, as P*Q suggests.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top Reply Quote Quick Reply Quick Quote
Quick Reply:
HTML is disabled
UBBCode is enabled




Moderator:  MagicCity, P*Q, Truffle Royale