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#2165995 - 02/27/18 04:43 PM CIP on Non-Customer check cashing
HubbaBubba Offline
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Curious as to if any of you conduct full CIP procedures (have them fill out a cip form which asks for DOB, SS#, mother's maiden name, physical address, etc.) on people who are NON-CUSTOMERS that come in to cash checks (can be on-us or not).

We do ask for photo id, but also do a full CIP on them. Is this necessary?

TIA

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#2166000 - 02/27/18 04:56 PM Re: CIP on Non-Customer check cashing HubbaBubba
Goodland Offline
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Joined: Nov 2015
Posts: 35
We ask for full CIP, Occupation, etc... the first time any non customer cashes an on us check. The reason is that our BSA system will need this information for CTR aggregation purposes. Every subsequent time we just enter the customer ID# or name to log the $ in the BSA system.

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#2166008 - 02/27/18 05:14 PM Re: CIP on Non-Customer check cashing HubbaBubba
Daisy Doodle Offline
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Southern U.S.
We do not cash checks for non-customers which are not on-us, and we have a $$ cap for on-us checks as well unless the branch obtains senior level approval (we'll swap them a cashier's check for the excess though). At $2,500.00 and up our system will prompt for CTR info, so that does the trick for us.

If the same non-customer is repeatedly cashing on-us checks, they are likely business purpose and we won't cash them at all for any amount. They can open a business account here and deposit them, or deposit them wherever their business account might be--again we'll swap them a cashier's check if they are worried about good funds or holds at their bank.

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#2166024 - 02/27/18 06:49 PM Re: CIP on Non-Customer check cashing Daisy Doodle
bcompliance Offline
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Originally Posted By Daisy Doodle

If the same non-customer is repeatedly cashing on-us checks, they are likely business purpose and we won't cash them at all for any amount. They can open a business account here and deposit them, or deposit them wherever their business account might be--again we'll swap them a cashier's check if they are worried about good funds or holds at their bank.


what if they are cashing their paycheck every other week?
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#2166059 - 02/27/18 08:02 PM Re: CIP on Non-Customer check cashing HubbaBubba
Daisy Doodle Offline
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Southern U.S.
Well, I would say cashing paychecks is not business purpose activity. And paychecks would be below our threshold typically.

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#2166083 - 02/27/18 09:08 PM Re: CIP on Non-Customer check cashing HubbaBubba
Oursisnottoreasonwhy Offline
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Posts: 503
Central Illinois
If they aren't establishing an account relationship there is no need to do CIP.

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#2166088 - 02/27/18 09:28 PM Re: CIP on Non-Customer check cashing HubbaBubba
Daisy Doodle Offline
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Southern U.S.
The elements for CIP are needed for CTR's, if one is required. I expect that is what the OP meant.

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#2166118 - 02/28/18 12:32 PM Re: CIP on Non-Customer check cashing Daisy Doodle
Elwood P. Dowd Offline
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"CIP" includes obtaining information and verifying information. How are you going to verify a name/TIN combination at the window?

If I am cashing a check at your bank for 10K or less and you ask me for my SSN please understand, I will make one up just to demonstrate the question is pointless.

My mother's maiden name? Mcgillicutti.
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#2166138 - 02/28/18 03:22 PM Re: CIP on Non-Customer check cashing HubbaBubba
BrianC Offline
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From now on Ken, I am going to refer to you as “Little Ricky.”
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#2166215 - 02/28/18 08:11 PM Re: CIP on Non-Customer check cashing HubbaBubba
RockChucker, CAMS Offline
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The Country
No, CIP is not required for non-customers.
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#2166279 - 03/01/18 12:40 PM Re: CIP on Non-Customer check cashing HubbaBubba
TryingtoComply Online
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The West
I've worked for banks that also did this:

We ask for full CIP, Occupation, etc... the first time any non customer cashes an on us check. The reason is that our BSA system will need this information for CTR aggregation purposes. Every subsequent time we just enter the customer ID# or name to log the $ in the BSA system.

HubbaBubba,

You referred to it as "CIP," but your bank is likely doing this so that it has the information on file in the event a CTR needs to be filed for aggregated transactions. It's just data collection for a possible future event. Teller systems that I've looked at allow for lowering the threshold from $10,000 to any dollar amount to cause tellers to collect the information on non-customers.

There have been many times that this feature enabled us to file a CTR with all the necessary information for non-customers hopping around to different branches. I actually had a non-customer complain to the FRB about this at one bank. We responded to the complaint and the FRB advised the non-customer that we were not breaking any law. They fully supported our efforts to have such a policy to enable us to meet our CTR filing obligations.
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