So I've got a unique situation that my loan department sent to me. The way I am understanding it is we are purchasing loans on the secondary market from a financial services firm that originates the commercial loans. They are asking me if we need to get beneficial ownership on these commercial loans. They received a "document" from this firm that basically states that the firm does not need to get beneficial ownership for these loans because they are not technically classified as a "covered institution".

My thoughts are that once we purchase the loans and set up accounts for them, they become our customer and are subject to the CIP regulations to include Beneficial Ownership. Am I correct in my assessment?

1020.100 (a) (2) Account does not include:

(ii) An account that the bank acquires through an acquisition, merger, purchase of assets, or assumption of liabilities; or