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#2253208 - 04/29/21 04:09 PM CIP & DL requirements - business signers
J_G Offline
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Joined: Dec 2010
Posts: 259
I just want to make sure I understand correctly that business account signers are not considered customers and therefore we are not required to get CIP and drivers license information on them. Is this correct?

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#2253211 - 04/29/21 04:32 PM Re: CIP & DL requirements - business signers J_G
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,229
Galveston, TX
That is correct unless they are also beneficial owner's then you have to meet those requirements.
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#2253213 - 04/29/21 04:38 PM Re: CIP & DL requirements - business signers J_G
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,694
Illinois
We cannot make a blanket statement such as this as there are circumstances when the USA PATRIOT Act will consider a signer to be a customer.

The CIP rule applies to a customer, which means:

An individual who opens a new account for:
An entity that is not a legal person, such as a civic club.

In other words, your CIP Policy should address circumstances where you will require CIP for authorized signers when you cannot verify the identity of an entity such as an unincorporated charity, club, etc.

Authorized signers of entities that you can verify such as corporations, partnerships and LLCs are not considered customers according to the USA PATRIOT Act, and it is up to your CIP Policy based on your CIP Risk Assessment whether to extend CIP requirements to these persons.
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