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Placement of the CIP Notice

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Question: 
Is a CIP notice required to be in place at each workstation where deposits might be accepted, for example, at an officer's desk or other location other than the teller line?
Answer: 

The CIP notice is NOT required at the teller line. It is an "account opening" notice. Customers must be notified about the fact that the financial institution will request information to verify their identities. The notification must be provided prior to the opening of the account. The notice can be provided orally, by posting a notice in the lobby where customers will be likely to see it, on a website, signs on desks, etc.

31 CFR 103.121(b)(5)(ii) states:
Adequate notice. Notice is adequate if the bank generally describes the identification requirements of this section and provides the notice in a manner reasonably designed to ensure that a customer is able to view the notice, or is otherwise given notice, before opening an account. For example, depending upon the manner in which the account is opened, a bank may post a notice in the lobby or on its website, include the notice on its account applications, or use any other form of written or oral notice.

First published on BankersOnline.com 7/24/06

First published on 07/24/2006

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