While the regulation does exclude federally regulated banks, banks regulated by a state bank regulator, etc from the definition of customer, do any of you still require the SSN and/or DOB of the signers/beneficiaries for ID purposes?

Most of the banks that we have as customers only have a time deposit account. So it is necessary to request this? AS BSA Officer, what info is actually required? If there is a regulatory citation, please direct me to it. Our Operations folks (who checks the new account reports) is demanding a SSN or DOB for identification purposes.

HELP!

Precisely because §103.121(a)(3)(ii)(A) states that a regulated bank is not a "customer," there is no regulatory citation that can be relied on to justify requiring SSN or DOB information on account signers when your depositor is a regulated bank. The long and short of it is that if your depositor is not a customer, you have no CIP responsibility under the regulation.

I imagine that your "operations folks" are demanding data because your bank's CIP says they must. In my opinion, when you're dealing with a bank, your policy should specifically exclude them from CIP coverage.

That of course does not mean that you should not know your customer and that the individuals in question have been authorized to open and maintain the account for the depositor.

"That of course does not mean that you should not know your customer and that the individuals in question have been authorized to open and maintain the account for the depositor."

Your stmt above would be satisfied with a resolution provided from the new acct platform system and/or some form from the bank/credit union that authorizes the individual(s) to act on behalf of the financial institution, right?

Right. And, if there is any question, a telephone call to verify the authenticity of the document.

THANKS, John!!!