Skip to content
GeoDataVision
Thread Options
#654742 - 12/20/06 04:00 PM Missing SSN
hollysiep Offline
New Poster
Joined: Feb 2006
Posts: 10
We aren't required to get SSN's for authorized Signers and POA's on accounts right?? Is there an easier way to note that they are only authorized signers and not account owners so that when we pull our list of names with missing SSN's, it won't include these names?

Return to Top
BSA/AML/CIP/OFAC Forum
#654812 - 12/20/06 04:52 PM Re: Missing SSN hollysiep
MagicCity Offline

Power Poster
MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Technically, according to the USAPA, authorized signers and POAs are not the customer, but alot of banks have stated in their policy that all signers on accounts are considered a customer for CIP purposes.
If your policy states that your customer is only the primary entity then you will be okay with examiners.
All that was as a side note.

To answer your question, you would have to sort your accounts by Primary Name only or by Line 1, depending on what system you have.

Return to Top
#655103 - 12/20/06 08:46 PM Re: Missing SSN MagicCity
cologirl@heart Offline
Gold Star
cologirl@heart
Joined: Mar 2005
Posts: 355
WY - still a CO girl, though
I know for our bank, we try to get CIP info on all signers, so that someone doesn't slip through the cracks as already being on the system...
_________________________
...it's all opinion, until proven otherwise...

Return to Top
#655139 - 12/20/06 09:08 PM Re: Missing SSN cologirl@heart
Becka Marr Offline
Power Poster
Becka Marr
Joined: Oct 2005
Posts: 6,152
I think MagicCity is right that you need to change the paramenters of whatever program you use to pull names, so that non-customers (authorized signer, POA, beneficiary, etc.) are not included.
_________________________
To avoid criticism do nothing, say nothing, be nothing. ~Elbert Hubbard

Return to Top
#655168 - 12/20/06 09:24 PM Re: Missing SSN Becka Marr
TXBSA Offline
100 Club
Joined: May 2006
Posts: 170
TX
Is there some sort of user defined field in your system that is blank that you could possibly use to define these customers? This would give you a field to sort on.

Return to Top
#655284 - 12/20/06 11:22 PM Re: Missing SSN hollysiep
Ted Dreyer Offline
Diamond Poster
Ted Dreyer
Joined: Apr 2001
Posts: 2,245
Keep in mind that the holder of a POA is the customer for CIP purposes if they open an account for a person who lacks legal capacity. In that case you would need their SSN.

Return to Top

Moderator:  Andy_Z