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#2241832 - 09/01/20 12:21 AM Guardianships and CIP
JackieW Offline
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Joined: May 2019
Posts: 20
When opening up a guardianship deposit account, for CIP purposes, who is the 'customer' that CIP information is obtained from and identity verification procedures conducted? The ward? The guardian? Both? #2) Whose information goes in the CIF record?

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#2241833 - 09/01/20 12:33 AM Re: Guardianships and CIP JackieW
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,318
Illinois
Since the ward lacks legal capicity, the guardian is your customer for CIP; however, for FDIC insurance/OFAC purposes, you may want to include the ward's information on your computer system as well.

The CIP FAQ's should be of help.

https://www.federalreserve.gov/boarddocs/srletters/2005/SR0509a1.pdf
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