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CIP on Municipal Account Authorized Signers

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Question: 
Are financial institutions required to obtain CIP information from authorized signers on municipal accounts?
Answer: 

If the customer is a government department or agency as used in 31 CFR 103.22(d)(2)(ii) or (iii) and as further explained in 31 CFR 103.22(d)(6)(ii), the CIP regulations don't require that you consider it a "customer" for the purpose of applying a CIP. However, if your institution's board-adopted CIP calls for such accounts to be subjected to the CIP process, your bank's program supersedes the regulation's exemption. If your policy subjects municipal accounts to CIP and subjects the signers on those accounts to CIP, you're required to follow your policy in that regard, too. As a personal observation, I imagine that the institution that subjects signers on municipal accounts to CIP requirements does not attract too many municipal accounts.

First published on BankersOnline.com 7/02/07

First published on 07/02/2007

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