Loans that are part of a participation --- are we required to get CIP? We didn't originate them.

I suggest obtaining certification from the originator stating their adherence to BSA/AML requirements, including among other things, CIP.

great idea..thanks

§103.121(a)(1)(ii)(B) exempts "An account acquired through an acquisition, merger, purchase of assets or assumption of liabilities."

From a FinCEN CIP Q&A

2. Are loan participations purchased from third parties and loans purchased from a car dealer or mortgage broker within the exclusion from the definition of “account” for loans acquired through an acquisition, merger, purchase of assets, or assumption of liabilities?

Yes, this exclusion is intended to cover loan participations purchased from third parties and loans purchased from a car dealer or mortgage broker. If, however, the bank is extending credit to the borrower using a car dealer or mortgage broker as its agent, then it must ensure that the dealer or broker is performing the bank’s CIP. (January 2004)

Prior thread beginning with the post by Key Lime... Asking for a certification you do not need should suggest to a third party reviewer that you don't understand the requirements of the regulation... CIP simply doesn't apply.