I read MackenzieS previous thread with interest. We use ChexSystems. Will we be required to run a check on all signers to a business account? Or.. is this simply an
internal policy decision? HELP.

The proposed rule requires you to gather certain information about each customer/authorized signer (name, date of birth, addresses, TIN, etc.).

Then, your CIP should identify on a risk-associated basis, how (or if) you will verify this data for each "customer." If you decide that the risk is low, you may decide not to verify the data you receive from that class of customers, or may use some less costly verification method.

So you have an option - but be ready to justfy your choices to examiners and Treasury.

Another point to consider- is ChexSystems verification your procedure for specific mandated items in the CIP (for example; OFAC screening.) If it is, then you would need to either verify authorized signers, or implement a separate process for meeting the mandates on these individuals.

To Anonymous - what is your policy going to be if you run chexsystems and the person who is a signer on the commerical account has an outstanding record? Will you deny the person from being a signer or accept the risk and go on?

I think that would be up to your bank. If they are OFAC related then of coarse you can not go on. Based on what I understand that should be something you address in your CIP program.