Outside of your CIP issue, unless you have a product that actually allows a single customer to hold a master account relationship and then set up their own sub-accounts - which they can name in any manner that they want too - I think I would be taking a pass on this arrangement. If all you are going to be doing is hold home improvement funds for a short period in each of these short-term sub-accounts, of what benefit is to the bank without a substantial fees being involved. Sounds like a maintenance nightmare.
From a CIP standpoint, these appear to be nothing more than a escrow account relationship.
10. Who is the â€œcustomerâ€ for purposes of escrow accounts?
An escrow account is an account generally established for the deposit of funds that are to be paid to a specified party on the fulfillment of escrow conditions or returned. If a bank establishes an account in the name of a third party, such as a real estate agent, who is acting as escrow agent, then the bankâ€™s customer will be the escrow agent.
The opinions expressed here should not be construed to be those of my employer: PPDocs.com