Answer:
That depends on the rules of your city and how they appoint people to open account on their behalf.
CIP excludes from the definition of ‘‘customer’’ the following readily identifiable entities: a financial institution regulated by a Federal
functional regulator; a bank regulated by a state bank regulator; and governmental agencies and instrumentalities, and companies that are publicly traded.
So unless your Bank's CIP policies includes such entities, this is not a CIP issue.