Regarding CIP compliance; do we need to get a updated and current copies of customers IDs after their account has been opened and those ID reach an expiration date?
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?
What is the entity type for a Trust? Would it be included as a Public Company?
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?)
Would an ICS (Insured Cash Sweep) account require a beneficial ownership form?
Does a bank need to obtain a Beneficial Ownership Certification form when opening account for a non-profit church?
Is the bank required to get two forms of I.D. for a signer on an account?
Does a publicly traded company need to have a CIP filled out for the company and the signers?
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.
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?