If the bank sells investment products how will the customer identificaton rules apply?

There is an ongoing question about this, because the bank is not really selling the securities - they are offered through some broker/dealer. The B/D is required to have its own customer identification program.

I'm thinking that the CIP for the B/D will apply to new investment accounts. This means that we will need to cinsult with our Borker/Dealer partners to determine what their CIPs require.