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#1728775 - 08/08/12 05:46 PM CIP
Mrs.Dawn Offline
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Joined: Jul 2009
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When a customer rents a safe deposit box and adds a signer (not a joint owner)to it, are we required to obtain all CIP information or is this person really not considered a customer? Also, if the box owner is deceased, is the signer allowed to access the box, or only a joint owner??

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#1728785 - 08/08/12 05:54 PM Re: CIP Mrs.Dawn
Elwood P. Dowd Offline
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Elwood P. Dowd
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The CIP regulation does not apply to a mere signatory, only a customer. The correct terminology for someone who has access to a safe deposit box, but is not a party to the contract is a "deputy" and a deputy would be the equivalent of a mere signatory. While the regulation's CIP requirements do not apply to a deputy, the language in your bank's CIP may require that all parties having access would be subject to your identification process.

The law regarding safe deposit boxes is a function of state court decisions, state statutes, and the specific terms of your contract. Generally, the powers of a deputy end with the death of the renter(s) who appointed him.
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#1728850 - 08/08/12 06:52 PM Re: CIP Mrs.Dawn
BFrame Offline
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BFrame
Joined: Nov 2011
Posts: 402
USA
Mrs. Dawn - I'm not sure which state you are located, but your state Bankers Association can probably be a great help to you with resources & training on safe box issues.
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