Vendor Guru Q&A - Operations

Aging infrastructure and siloed platforms across in-branch and remote payment channels cause friction, surging costs and poor user experiences

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Latest Operations - CIP Topics

A customer passes and an estate account is opened at another institution by the appointed executor of the deceased. We receive the death certificate and letter of instruction from the executor to disburse the funds to the estate at the other bank. Are any CIP forms needed for the executor or anyone else on our end?

Classify a Trust

05/22/2022

What is the entity type for a Trust? Would it be included as a Public Company?

Control Prong Sheet for Sole Prop Account

01/30/2022

When opening a sole proprietorship checking account, does the bank need to collect signed documents for the control prong. (Not a Beneficial owner sheet, but the control prong sheet?)

ICS Acct Require Beneficial Ownership Form?

11/14/2021

Would an ICS (Insured Cash Sweep) account require a beneficial ownership form?

Beneficial Ownership Certification Form

06/21/2020

Does a bank need to obtain a Beneficial Ownership Certification form when opening account for a non-profit church?

2 Forms of I.D. for a Signer on an Account?

12/15/2019

Is the bank required to get two forms of I.D. for a signer on an account?

CIP for Publicly Traded Company

12/01/2019

Does a publicly traded company need to have a CIP filled out for the company and the signers?

CIP for Sole Proprietor- OFAC or Full Search?

08/18/2019

We use a vendor's product for CIP purposes at the bank. When running a sole proprietor account, is there a reason we should be doing the full search or is OFAC alone sufficient? The same would go for unregistered organizations.

Clarification on Beneficial Ownership Rule

04/28/2019

I need clarification on the beneficial ownership rule. If we have non-profit or charity accounts that are not legal entities, do we have to do the control prong? What if their paperwork does not have them classified as a corporation or LLC but they have a separate EIN? Do we then do the control prong? And what if the account is very old and they don't have the actual papers stating if they are incorporated, etc. but have a separate EIN? Does the EIN make a difference?

IRS Levy for Individual-No Personal Account

11/04/2018

We received an IRS levy for an individual. We have no personal account, but there is an account where the individual is the sole owner on a business account and incorporated. Does the levy effect this account? And do the new Beneficial Ownership regulations impact this at all? This individual is really using this as a personal account and even deposits Social Security checks into it.

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Are we required to put a lender’s NMLS ID # on ads?

03/26/2023

Must a lender’s NMLS ID # be included in advertisements?

What is a “repayment” to an IRA?

03/23/2023

Yes, there are certain situations like qualified reservists and disaster relief when an IRA can be repaid to the plan. ------------------------- Learn more about Deborah Crawford’s <a href=”https://www.bollearningconnect.com/ira0423”> IRA Operations Update 2023 </a> webinar.

Latest Operations - CIP Topics

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