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Member of Publicly Traded Company Exempt from CIP?

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If a person is a member of a publicly traded company, do they fall under the same CIP regulations of the Patriot Act? I have a potential customer claiming that due to his position within a publicly traded company that he does not have to provide this information.

If this individual is opening a personal account at your bank, he will have to provide the appropriate CIP information. His position or title does not exempt him when opening accounts outside of the business. If this person is opening a business account (for a publicly traded company) and he is an authorized signer on the account, you would not have to CIP him.

Editor's Note: Although there would not be a regulatory requirement to "CIP" an authorized signer on a business account for a publicly-traded company, if the bank's board-approved CIP policy calls for the application of CIP ID verification on such individuals, the bank's policy should be followed. Whether such a policy is ideal is a matter for the bank's board to determine.

First published on 3/13/06

First published on 03/13/2006

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