I have been reading 31CFR 103.121(a)(3)(ii) to assist with determing if Public Funds Time Deposits are exempt from CIP rules. Can someone please shed some light on CIP requirements for these customers?

Thanks.

Start with your bank's CIP requirements. If they say you have to collect ID information, don't even bother with the regulation. You've got a policy to follow.

The regulation says that the term "Customer" does not include persons described in "§ 103.22(d)(2)(ii)-(iv)." That includes "[a] department or agency of the United States, of any State, or of any political subdivision of any State."

If your depositor is a political subdivision of a state, the CIP regulations do not require you to "CIP" the depositor.

Thanks much the info. Our CIP procedures do not address Public Funds at all. I will however, strengthen them to specifically exempt them.

I was originally looking at these accounts under my ID Theft Red Flag regulation 'eye' and ruled them out as being a covered account. But I then thought....oh no. what about BSA.

Have a super day,
Lori