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Perform CIP When Changing Signers on Account?

Answered by: 
Brian Crow

Question: 
Our bank has an account that is changing signers. The new signers have never before been customers of ours or signers on any of our existing accounts. The signers hold executive positions for the company for which we hold the account and it is changing signers. The company is publicly traded on the NYSE. Do we need to perform CIP on these new signers?
Answer: 

The business entity is your customer for CIP purposes, not the individual signers. However, if your institution's board approved CIP policy and procedures require CIP data to be obtained on account signers, you must adhere to your own policy.

First published on BankersOnline.com 1/28/13

First published on 01/28/2013

Filed under: 
Compliance
Filed under compliance as: 
CIP
IT

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