I know a definition for signatory might be included in the final regulation but, for now, how are you interpreting that definition under the CIP program. If you have a corporate customer, do you verify the identity of every person who could sign on a loan or deposit account even though they are signing in their corporate capacity. Or since we have obtained the identifying documents for the corporation do you stop there.

Thanks.

I am going with a broad interpretation for now. Anyone who signs on the account or is authorized to make transactions, i.e. wires, telephone transfers, guarantor, etc.

May have to change this later.

I'm reading it to mean every person who has authority to move money on the account.

In the Section-by-section analysis that precedes the text of the proposed regs, in discussing the definition of the term "customer" it says: "The proposed rule also defines a "customer" to include any signatory on an account. Thus, for example, an individual with signing authority over a corporate account is a "customer" within the meaning of the proposed rule."

The proposed rule section by section analysis states "an individual with signing authority over a corporate account is a 'customer' ". It appears we would have to obtain & document identification for each signer on the corporate account.

Same response-we are treating every person, authorized signer, guarantor, etc. as an indivdual. So if a corporation has a loan and has three guarantors, you need to verify 4 folks: 1 for the corp. entity and 3 for each person who guarantees.

And probably the Corporate Secretary if they are not one of the 3.

Anyone have an idea when the final reg will be out? We are revising our current BSA policy as we speak but we have a few "ol' timers" (I dont mean in age necessarily) that don't want to amend policies until the final reg comes out. These people greatly slow down the pro-active process!

We haven't even started. "No sense in writting anything until the goverment issues the final rule." So I sit and wait and worry that I'll have one week to get them written and implemented.
The good news is we already do most of the stuff. It's just getting it documented!

I've got the policy squared away. I'm just waiting on the final rule before I write all of the procedures.

You make the rest of us feel bad.

I'm not trying to...

So does this mean our BSA/AML policy is now to become our BSA/AML/CIP policy?

Anyone care to share their BSA/AML/CIP policy?