You are correct, our Bank’s CIP policy does apply to account owners and signers. I’ve inherited the policy and have for the most part been very cautious of making revisions to a policy that has received good comments in examinations and audits, unless regulatory revisions are required.
However this appears to be a time where changes are needed. So the questions arise when anticipating the revisions, should I revise to exclude for online View only authorities, or everyone, since the regulation doesn't apply anyway. I haven’t received many comments regarding CIP and online banking authorities, perhaps banks are complying with the regulation as it states.
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Nana, CRCM