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#2282734 - 03/27/23 08:48 PM CIP - Consumer Account with Business Address
4ComplianceSake Offline
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Joined: Mar 2023
Posts: 22
Customer wants to open a consumer account using a business address. They do not own the business. It does not appear that there is living quarters in the business. The BSA manual does not directly address this. How does your institution handle this? Do you perform enhanced due diligence?

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#2282738 - 03/27/23 09:00 PM Re: CIP - Consumer Account with Business Address 4ComplianceSake
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Just tell them no? Do they not have a residential address? I would just tell them to move on.
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#2282766 - 03/28/23 07:27 PM Re: CIP - Consumer Account with Business Address 4ComplianceSake
ColoradoAML Offline
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Joined: Mar 2018
Posts: 338
If you're not comfortable with it, say no, but this seems like it fits squarely in the regulatory requirements:

§ 1020.220 (A)(3)(i)

(A) the bank must obtain...

(3) Address, which shall be:

(i) For an individual, a residential or business street address;

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#2282796 - 03/29/23 05:17 PM Re: CIP - Consumer Account with Business Address 4ComplianceSake
John Burnett Offline
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John Burnett
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Cape Cod
If it's the customer's business street address, yes. But if they don't work there, not so much.

And be wary if the street address is for a private mailbox service like those offered by the UPS Store and others. That is often a red flag for fraud.
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#2282797 - 03/29/23 05:20 PM Re: CIP - Consumer Account with Business Address 4ComplianceSake
John Burnett Offline
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John Burnett
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Cape Cod
For example. I might want to open a personal account and not have the statements or other mail come to my home address. So I give the bank the address of the business at which I work. That's squarely within the CIP rule. (Of course, I work at home, so it's a bad example!)
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
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