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#82904 - 05/27/03 08:24 PM CIP - reasonable belief that we know the true id..
Love those Regs Offline
Gold Star
Joined: Apr 2002
Posts: 290
Southern State
What are others doing (saying is acceptable) to ensure they "know the true id of the person" in regards to the CIP definition for customer and those with existing accounts?
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Opinions are mine and subject to change frequently

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General Discussion
#82905 - 05/28/03 02:34 PM Re: CIP - reasonable belief that we know the true id..
Anonymous
Unregistered

For existing customers, we are going to attempt to scrub our files to obtain the four pieces of required information. If an existing customer opens a new acocunt and we don't have all of the Big 4, then we are going to require this information. If we don't have a record of identification (e.g, driver's license), then we will ask for that as well. We may not always get ID on existing customers if they are well-known, but we feel that we cannot form a "reasonable belief" without the Big 4.

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#82906 - 06/02/03 04:10 PM Re: CIP - reasonable belief that we know the true id..
BankerMama Offline
Diamond Poster
BankerMama
Joined: Jun 2001
Posts: 1,543
Is it really necessary to go to such lengths? If a customer has done business with us for say....a year. Wouldn't we have a "reasonable belief" that we know who we are dealing with?

I'd LOVE some regulator comments here. Any Anon Regulator out there?

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#82907 - 06/02/03 05:09 PM Re: CIP - reasonable belief that we know the true id..
Princess Romeo Offline

Power Poster
Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
"Reasonable Belief" is whatever you think that it is. You need to articulate what your standards are for "Reasonable Belief" in your CIP policy. The regulation itself was purposely written to leave that standard open for each institution to set for itself.

Does this mean that you won't be second guessed by an examiner? Probably not, since any self-set standard is open for criticism. IMHO, this will be a constantly evolving area, and I would guess at some point down the road, you will find a general consensus as to what constitutes "Reasonable Belief."

Also, I think the standard will be different for large regional banks vs. small, community-based institutions. For instance, if you have an officer that serves on the same YMCA/March of Dimes/local Chamber board as a promenient business customer, then I would say your "Reasonable Belief" is more substantial than someone who is never seen in our outside of the bank.
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CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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