Answer:
First, determine whether the tribe is recognized by the U.S. Bureau of Indian Affairs (BIA). If it is, you may treat the tribe as a unit of government. Then, check your bank's board-approved CIP policy and program. If there are ID requirements that are specific to Indian tribes and/or governments and government agencies, adhere to those requirements. The CIP regulations do not include units of state, local or federal government (that includes recognized tribes) as customers for the purposes of those rules. Your bank's CIP may still impose some form of ID requirement. If the tribe isn't recognized by the BIA, treat it as you would any other group or business according to your CIP.
First published on BankersOnline.com 1/22/07
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