Answer:
The FFIEC published this FAQ on CIP some years ago. It's important to also verify what your bank's CIP requires or ensure it conforms with this.
Q. Does the CIP rule prohibit a minor from opening an account?
A. No, the CIP rule does not bar a minor from opening an account. It merely states that the bank’s “customer” is the individual who opens the account for an individual who lacks legal capacity, such as a minor. In other words, if a parent opens an account for a minor, the bank’s customer is the parent. If, however, a minor opens the account, then the minor is the bank’s customer. For example, where a bank sends its employees to elementary schools so that students may open savings accounts as part of a program to promote financial literacy, a student opening an account is the bank’s customer. In this situation, as for all customers, the bank should get the name, address, date of birth, and taxpayer identification number of the student. Since verification procedures are risk-based, banks can use any reasonable documentary or non-documentary method to verify a student’s identity. In this case, the bank might verify a student’s identity using a student identification card or by having the student’s teacher confirm the student’s identity.
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