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#39620 - 10/30/02 06:01 PM Another CIP question
Kara S Offline
Platinum Poster
Joined: Oct 2002
Posts: 927
Milwaukee, WI
I know-not again! Since I now have the time, I am in the process of evaluting my CIP program. The proposed CIP rule defines persons, "including any signatory on an account, such as an authorized agent for a business entity". What about beneficiarys, POD's, and POA's. How is everyone else handling these?

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General Discussion
#39621 - 10/30/02 06:20 PM Re: Another CIP question
Anonymous
Unregistered

Beneficiaries - no, they have so signatory authority. Fiduciaries (such as conservators, executors, agents, attorneys in fact, etc.) - yes, they have authority over the account.

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#39622 - 10/30/02 06:24 PM Re: Another CIP question
Kara S Offline
Platinum Poster
Joined: Oct 2002
Posts: 927
Milwaukee, WI
Thank you!
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#39623 - 10/31/02 03:09 PM Re: Another CIP question
complyguy Offline
Gold Star
complyguy
Joined: May 2001
Posts: 494
PA
I just wanted to tack on to the original question. Yesterday, I attended a CIP seminar whose speaker insisted that anyone who routinely does banking transactions for an account must undergo ID procedures even if the person is not an authorized signer to the account.

Since I never read that in 326 and never heard in mentioned in any of the numerous CIP threads here, I questioned the speaker, but she was adamant that she was correct. I still can't find anything. Comments?

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#39624 - 10/31/02 03:15 PM Re: Another CIP question
Anonymous
Unregistered

Another self important individual that makes up their own rules. If the individual conducting transactions does not have "signature authority" there is no duty to identify them. Many companies send employees to the bank to make deposits. It would be impossible for us to keep records of every individual that comes to the bank.

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#39625 - 10/31/02 03:17 PM Re: Another CIP question
RVFlyboy Offline
Power Poster
RVFlyboy
Joined: Oct 2000
Posts: 5,991
Soaring over Georgia
The proposed regulation just deals with account opening and really only addresses signatories on the account.

Although not required under the proposed regulation, anyone conducting business in your bank should probably be subject to some type of identity verification just as a matter of prudent business practice. The regulations also do not require identity verification of non-customers cashing checks in your bank either - but I bet you have a procedure in place to do that very thing if you cash checks for non-customers.
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