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CIP Required on New Loan but Already Custodian?

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Question: 
Is a CIP required on a NEW loan customer who is already a custodian on his son's account our bank?
Answer: 

If CIP was performed on the individual as part of his custodial account, you would not be required by regulation to perform CIP. You would also need to look to your CIP program to determine if the program requires any re-performance of CIP or update to CIP information for existing customers.

First published on BankersOnline.com 3/25/13

First published on 03/25/2013

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