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In Response To:
Thread Starter: rlcarey
Title: Re: CIP on joint accounts

Unless the joint accountholder is not a customer and I have no idea how your could justify that, you need to follow your CIP on every accountholder on the account.

1020.220(a)(2)(i) Customer information required —(A) In general. The CIP must contain procedures for opening an account that specify the identifying information that will be obtained from each customer.