CIP on Loans Via Acquisition

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Question:

If a bank acquires loans through an acquisition, are new CIPs required? What would be involved from a BSA standpoint?

Answer:

No.

"Under the final rule, the definition of "account" excludes accounts that a bank acquires through an acquisition, merger, purchase of assets, or assumption of liabilities from any third party. Treasury and the Agencies note that the Act provides that the regulations shall require reasonable procedures for "verifying the identity of any person seeking to open an account." Because these transfers are not initiated by customers, these accounts do not fall within the scope of section 326."

First published on BankersOnline.com 9/21/09