If our bank purchases loans and takes on the servicing of those loans, CIP says that those are now customers of the bank because they have a new banking relationship with us, and so CIP is required.
CIP doesn't say this.
§1020.100(a)(2) (ii)
Account does not include:
(ii) An account that the bank acquires through an acquisition, merger, purchase of assets, or assumption of liabilities;
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