The grantor is not your customer and therefore not subject to CIP or CDD requirements.
BSA responsibilities aside, hopefully there is something in your underwriting procedures about verifying that the representative of the LLC signing the collateral agreement has the authority to do so in the LLC resolution of authority, operating agreement, etc, lest you have some random person pledge collateral for which they do not have the authority and you find yourself with a useless collateral agreement.
Last edited by BrianC; 07/19/19 09:22 PM.
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