I think I know the answer, but just want to confirm it. We have a safe deposit box leased to a couple. They have named their daughter as deputy. In determining if we should have applied CIP to the deputy, the deputy is actually similar to an authorized signer on a deposit account correct? If so, we would not need to apply CIP to the deputy as our CIP program only applies to account owners. Does this sound correct? Or am I mis-interpretting the function of the deputy appointment?

Your analogy is valid; the regulation only applies to a "customer." So, you would only apply your CIP process to the daughter if your bank's CIP required it.

Thank you so much!

FYI

I have had this discussion at a previous bank; since they are not "customers" when they are put on the box you can not use the term "existing customer" when they open a deposit account.