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CDD for Beneficial Ownership: Participant Loan?

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Question: 
Does the new CDD for Beneficial Ownership play into a participant loan? How would you get this information?
Answer: 

Per the CIP FAQ's, the purchase of a participation loan from a third party does not constitute the opening of a new account. The CDD requirement to identify beneficial owners would not apply.

First published on 04/02/2017

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