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Is He an Established Customer for Purposes of CIP?

Answered by: 
John Burnett

Question: 
We have a customer who wants to open an account in the name of his "Family Trust" using his SSN. Are we required to go through the CIP process, since he is already an established customer?
Answer: 

The family trust is a new entity to you. It may be appropriate for the trust to use the individual's SSN, assuming it is a revocable "grantor" trust.

You don't have an established customer relationship with the trust, so CIP procedures will apply. However, your CIP program may provide for somewhat limited verification of ID in instances like this.

First published on BankersOnline.com 07/04/05

First published on 07/04/2005

Filed under: 
Security
Filed under security as: 
CIP
ID
IT
SSN

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