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NonCustomers & CIP

Question: 
I have an issue that some of our tellers are not understanding. Tell me from the compliance standpoint of CIP how this should be handled. We have always required ID on all people, customersif you do not know them and noncustomersno question. However, some tellers are not asking for ID on noncustomers because they have been coming into the bank for the last 5 years to cash their check so they do not get their ID. How do you suggest we handle this situation?
Answer: 

Answer by Andy Zavoina:

For CIP you will not have an account relationship for those cashing checks. CIP is essentially not applicable to them. But if your internal policy is more restrictive, as it certainly can be, they should be following that. You want to mitigate your risks with that ID verification and justifiably so.

Answer: 

Answer by John Burnett:

And from a CIP perspective, if that "wellknown" person who has been cashing his check for ten years finally decides to open an account relationship with you, it won't matter that your staff knows him. He is not a "current customer" so you'll have to gather his ID data and verify it according to whatever standard your CIP has established. It doesn't matter whether this new customer is married to your head teller, or is a celebrity like "J Lo." You verify ID if he or she is opening an account.

Answer: 

Answer by Barbara McGuire:

Andy and John are right CIP is for "customers"...Also keep in mind that new FFIEC exam procedures for the regulators will be taking a closer look at whether your bank is practicing your WRITTEN procedures. FDIC made their announcement this past week.

As John indicated, your tellers should be getting ID if your procedures require it

First published on BankersOnline.com 008/18/03

First published on 09/23/2013

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