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New CDD Rule: Identify Authorized Signers-Business

Question: 
With the new expectations of the CDD Rule that goes into effect next month, are we required to identify authorized signers on business and organization accounts?
Answer: 

by Jim Bedsole:

Only to the extent that any of those authorized signers meet either the ownership or control prongs of the beneficial ownership rule. Otherwise, identification of authorized signers should continue to follow whatever your BSA policy specifies for such individuals.

Answer: 

by Ken Golliher:

I have seen a software vendor touting the idea that banks should treat authorized signers as they would beneficial owners. I assume that's just a ruse to help them peddle their product.

As noted, the new regulation makes no such suggestion.

First published on 04/22/2018

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