A question for the group. Customer Identification Files (CIFs) or Portfolios...whichever you go by. On a non-consumer account, do you create a CIF for all signers? We've been having a discussion and discovered we do not have it in writing, that I have found. On Consumer accounts, any owner must have a CIF for 314a and the SDN list update scans. But for a non-consumer account do all signers need one since they are not technically customers?

I asked out auditor and have the impression it is up to us. Obviously CIP applies to everyone on account opening. But, I have come to the conclusion only the entity, any beneficial owners and any signer with a debit card, need a CIF created. What are your thoughts?

The CIP rules do not require an institution to CIP authorized signers and guarantors. That is left up to each institution's individual CIP. I've worked for banks that did do full CIP and some that didn't. OFAC is risk-based.

At most banks I've worked at (including a bank >$10B in assets), all authorized signers and guarantors had a CIF with a code to indicate their relationship to the account. All were scanned for OFAC.

This thread is old, but hoping for more clarification. If a CIF is created for all signers, do you then require all their personal information (DOB, SSN, residence address, ID info.)? If not, how do you work around your system to not have, for example, the signers SSN? Thanks

Since none of that is required for an authorized signer, it is really up to you.