Sorry to kick the (almost) dead horse. If you accept the fact an entity may not be a "financial institution" under the current definition (eg., mortgage company)and would not be subject to the CIP rule if standalone but that the same entity, if a subsidiary is subject to CIP because of its status as a bank sub, can you have a contract and a safe harbor reliance on the sub's CIP procedures when they don't meet the definition of a financial institution? Sorry for the run on sentence.