For CIP, regarding joint consumer accounts, which of these do you think best describes the actual legal requirement?
A. CIP applies to “a person seeking to open a new account” or
B. CIP applies to “every person who will be an accountholder”?
To phrase that another way, does CIP apply to both people on a joint account, or only the one of them that was our primary contact for it?
I’m asking about legal requirements rather than policy requirements, because I can get policy changed if ours is overly strict. (Ours says “B” at the moment...which I'm thinking may be unusual, based on how I've seen other financial institutions treat CIP a little more laxly than I do.)
I may be over-thinking it, but picture a joint account where Mr. Customer applies in person while Mrs. Customer is at work and never makes an appearance at the branch. Does the law actually require us to apply CIP to the non-present joint owner, Mrs. Customer?
Obviously, for customer service and operational needs, we are going to want to gather CIP-style info on Mrs. Customer regardless. I'm not asking about best practices or what is necessary other than what the law requires. In terms of what our written policy actually must cover by law, is Mrs. Customer somehow less subject to CIP than Mr. Customer, in that she (arguably) wasn’t the person who was “seeking to open a new account”?
Do you, at your institution, routinely apply CIP only to the "first" person listed on a joint account? Do you routinely verify it only for the first person listed?
(Tip: Have a look at the reports your institution uses for this. If you only see one name on each row, well...you might be in the option "A" camp anyway, regardless of what written policy requires.)