I am wondering what others do when requested to open an account for a newly formed corporation or LLC and the only address that they have as yet is the address of the incorporator. Would you open the account or tell them to come back when they have a verifiable physical address?

If you CIP program allows it, a home address for a business (and vice versa) is allowed under the law/regulation. What if the business will never have a separate address? They probably used the home address for the formation documents and you can verify against that.

The addrress provided is not the home address of the owner of the business; it is the business address of the attorney or other individual who filed the paperwork for the business.

Okay. There is nothing that says a business cannot use the home address of the owner, and that is quite common especially in formation stages.

If they are working out of that location and receiving mail there, and you have no reason to suspect fraud, you can use that address. Depending upon your CIP program, you can have various options available including a visit or sending mail to that address.

You do not have to validate all CIP elements, just enough to verify that you have identified the customer - but again how you do that hinges upon your CIP program.

I agree, but might expand it to the addresses of all of the beneficial owners; e.g. 25% or more. (The regulation acknowledges this possibility, but I believe your CIP should reflect it as well.)

The address of the incorporating attorney means nothing in terms of CIP and, perhaps, anything else.