Really a great question. Reliance on a another FI isn't something I have seen done much, though I helped manage this once a long time ago.
First, does your CIP Policy have language that specifically allows you to rely on another FI for CIP? If not, I'd say you need to stop there.
If your policy does address this, it would need to comply with these provisions, as outlined in the FFIEC BSA/AML Exam Manual:
[i]-Such reliance is reasonable under the circumstances;
-The other, relied-upon financial institution is subject to a rule implementing 31 USC 5318(h) and is regulated by a federal functional regulator;42 and
-The other financial institution enters into a contract requiring it to certify annually to the bank that it has implemented its AML program, and that it will perform (or its agent will perform) the specified requirements of the bank’s CIP.43[i]
As you know, CIP is always a hot topic with regulators and if it were me, I would conduct a LOT of due diligence as deficiencies in this area can cause big problems.
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com