Speaking at the ABA MLES conference last year, Lisa arquette, Chief of the FDIC's Special Activities section, said that the CIP regulation does not include guarantors as "customers." She added, "Section 326 does not eliminate prudent underwriting for banks" and that normal underwriting mehods would require banks to adequately identify the guarantor. She emphasized that identifying the guarantor was a "separate issue entirely" from CIP compliance.
In summary, the law does not require you to CIP a guarantor, but common sense does. If the presence of a guarantor is necessary to make the loan a bankable deal and you want the loan to be valued at 100 cents on the dollar, the file should clearly indicate the guarantor's identity and credit worthiness.
From page 138 (document, not pdf) of the current examination procedures:
All loans are considered to be accounts for purposes of the Customer Identification Program (CIP) regulations. For loans that may pose a higher risk for money laundering and terrorist financing, including the loans listed above, the bank should complete due diligence on related account parties (i.e., guarantors, signatories, or principals).
It talks about due diligence, not CIP, on guarantors. (Due diligence would entail much more effort than CIP.) The comment is clearly in reference to situations where BSA/AML risk is identified.
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.