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#27373 - 08/08/02 07:55 PM CIP
Anonymous
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Our community has many senior citizen developments. Many of these individuals open their accounts and wish to have a son or daughter on their account, but they live in a different state. How are we to handle the CIP requirements in this type of a situation?

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#27374 - 08/08/02 08:12 PM Re: CIP
John Burnett Offline
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I expect we'll see a lot of different variations on this theme, so I'm gonna bookmark this and the long CIP thread so I can refer posters to them more readily.

Anyhow, the proposal suggests that your CIP include in it a risk-based ID verification procedure. So, you'll need to obtain all of the ID data elements for the out of area (OOA) signer, but you will provide for a reasoned approach in the CIP for how much and whether you'll need to verify all or part of the data. If the account (product type or customer type) is one that you think is riskier than others (fraud, money laundering, terrorist financing), you'll probably require more verification than for a garden variety business or personal account.

Be reasonable in your planning. Think about the risk involved in ID for the type of account you're dealing with. It's probably fairly low. So perhaps you won't want to verify ID data on this person. Maybe you ask them to supply you with a photocopy of their license so you can compare signature. Whatever works for you.

If the account is for a Wal*Mart that's going to be signed on by high-muck-a-mucks at corporate HQ, you're probably comfortable without verifying much other than getting a corporate resolution. But if it's a charity with a HQ in the Middle East, you'll want to document the hell out of any and all IDs you get.

Good luck to us all!
Last edited by John Burnett; 08/08/02 08:16 PM.
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#27375 - 08/08/02 08:13 PM Re: CIP
redsfan Offline
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Presuming the proposed rule is finalized as is, You will need to gather the information required by 103.121(d)(2)(i)(A) about the child.

Then, you can make a risk-based decision in your CIP on whether or how you verify that data, and what sort of documentation you request to do it. So, to a large extent, what you do is up to you and your assesment of the risks associated with those type of accounts and customers.

There is a similar thread elsewhere in this forum. You might want to check the comments there.
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#27376 - 08/08/02 09:24 PM Re: CIP
BrendaC Offline
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Sweet Home AL
One idea may be to ask the joint owner or convenience signer to have their signature notarized. We could also ask for a certified copy of the individual's ID. I know we have asked our customers to have their signature notarized when they are out of state for some of our CD accounts. That being said, on a joint account, will you open the account as a single-owner account and maintenance it to a joint account when the replacement cards are properly signed and returned? Or will you open it as a joint account from the very beginning?

And...We probably need to go ahead and be thinking about how we would handle a similar ID request from one of our customers. Would you make a copy of your customer's ID and mark it as a certified copy of the original so they could send it to Mom's bank? Would you charge for the service? Would you restrict the service to only established customers or provide the service to non-customers as well?

Another thing that makes you go...hhhmmmm.
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#27377 - 08/09/02 03:49 AM Re: CIP
Princess Romeo Offline

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In reply to:

Would you make a copy of your customer's ID and mark it as a certified copy of the original so they could send it to Mom's bank?



I sure as heck wouldn't! You need to check state laws regarding "certified copies" of identification documents. I know that in California there are certain documents that can NOT be marked "certified" on the copy. Only the original issuer of the document can certify a copy.

Talk about potentially opening the door to fraud.....
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#27378 - 08/09/02 05:18 PM Re: CIP
BrendaC Offline
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See what I mean?? We have a lot of homework to do before we are able to accurately address the compliance issues surrounding a Customer Information Program. You obviously know the law in California--I have absolutely no idea if similar laws exist in the many states where our customers live.

Maybe we could get a affidavit from an out-of-state customer swearing the attached copy of the ID is valid. But then, of course, that means nothing to the bad guy who is sending you the fake ID. But then a customer we know is also on the account, so how high do we perceive the risk to be...I'm confusing myself.

Perhaps some additional guidance will come out of our comment letters to our regulators on CIP requirements.
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#27379 - 08/09/02 05:40 PM Re: CIP
JacF Offline

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Long gone are the days where we could settle for "Epstein's ID is valid. Signed, Epstein's mom."

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#27380 - 08/09/02 05:51 PM Re: CIP
Andy_Z Offline
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In reply to:

Long gone are the days where we could settle for "Epstein's ID is valid. Signed, Epstein's mom."




Someone tries that, you tell them "up your nose with a (326) rubber hose".
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#27381 - 08/09/02 06:02 PM Re: CIP
Ice Man Offline
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JacFSB...Just curious...(and it's Friday)...what does the reference to "peanuts" on your signature discloser mean?

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#27382 - 08/09/02 06:09 PM Re: CIP
NotALawyer Offline
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...and may contain peanuts.

That is too good!

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#27383 - 08/09/02 06:45 PM Re: CIP
JacF Offline

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Peanut allergies are among the most horiffic and most lethal food allergies around. As such, food products that are produced/handled where peanuts are used require this little 'may contain penauts' warning. I have seen this disclaimer in some pretty odd places, so I thought I'd add one more!

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#27384 - 08/09/02 08:00 PM Re: CIP
waldensouth Offline
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Once, a long time ago, in the pre-326 galaxy, someone published a link to a site that showed pictures of various types of ID. Does anyone know where that link is? Please share
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#27385 - 08/09/02 08:16 PM Re: CIP
DawgFan Offline
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At some point prior to my typing this message, I passed within at least 100 feet of peanuts. Be careful.
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#27386 - 08/09/02 08:44 PM Re: CIP
redsfan Offline
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The Pennant Race
I want you all to know that reading all these references to peanuts is causing me to have an allergic reaction to the forum. Since I am not responsible for having read the posts, and you knew or should have known that making the references could spark my reaction, I will be forced to file suit alleging negligence on your part for the peanut posts. NOT!

It's definitely time for the consumption of multiple adult beverages! Have a nice weekend everybody!!
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#27387 - 08/09/02 09:04 PM Re: CIP
John Burnett Offline
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Cape Cod
Cheers!
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