Good Morning All!

I recently came on board of a small local bank. I am re-writing policy and procedures for BSA/AML and noticed a gap and have, hopefully, a simple question.

The bank purchases loans from BHG. The master agreement does not address CIP/BO Collection. I know, to an extent, we are able to rely on third parties to collect CIP. The loan is entered into our system to get onto our books, but we do not service, take payments, or have anything to really do with the loan. In examining the files provided under the first loan purchased since I've been here, I noticed that Beneficial Ownership was missing from the documents provided. Should I be concerned? My assumption is that they have an AML Program/Requirements and are federally regulated. Should I be relying on them and not worrying about it? Should I be obtaining a certification from them annually they are performing their necessary CIP obligations?

What are my obligations here?

My initial interpretation is that these accounts are exempt. That the FFIEC manual states that an account that the bank acquires is not considered an account for purposes of CIP.

First, would that entity be considered a Covered Financial Institution as defined by the CDD Rule? Second, a purchased loan isn't considered an account for CIP/BO.