CIP Notices on State Chartered CU's Website

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Question:

Is it a requirement for a state chartered credit union to post CIP notices on their website? We have it on the membership form on the website but not on the website itself. Compliance wants to get it put on, but Marketing is refusing because of what they call, "esthetic considerations." Where I can find the text on this topic?

Answer:

Either solution is acceptable. You will find in 31 CFR 103.121(b)(5) the following language:

Notice is adequate if the bank generally describes the identification requirements of this section and provides the notice in a manner reasonably designed to ensure that a customer is able to view the notice, or is otherwise given notice, before opening an account. For example, depending upon the manner in which the account is opened, a bank may post a notice in the lobby or on its website, include the notice on its account applications, or use any other form of written or oral notice.

As you can see, as long as the customer is able to see the notice before opening an account, you're good to go.

First published on BankersOnline.com 11/27/06