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#636958 - 11/10/06 04:16 PM CIP and Secondary Market Mortgages
zippy1 Offline
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Joined: Oct 2006
Posts: 16
If customer has no other contact or accounts with your institution other than the secondary mortgage market, do you need to obtain complete CIP information, scan it into your system and follow all other rules about retention even though you will never have the loan on your books?

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BSA/AML/CIP/OFAC Forum
#636959 - 11/10/06 04:31 PM Re: CIP and Secondary Market Mortgages
Big Dog Offline
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Joined: Mar 2005
Posts: 2,659
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I believe if you originated the loan, you need to take care of the CIP. The purchaser of the loans is relying on your procedures to handle CIP.
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#636960 - 11/10/06 06:49 PM Re: CIP and Secondary Market Mortgages
MadisonCali Offline
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Joined: Jun 2006
Posts: 2,515
We sell a majority of our mortgages to the secondary market, and we do have CIP procedures in place.
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#636961 - 11/10/06 07:43 PM Re: CIP and Secondary Market Mortgages
zippy1 Offline
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Joined: Oct 2006
Posts: 16
Thanks to all for responding so quickly!

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