Answer:
Each institution sets its own Customer Identification Program procedures. You determine on a risk basis what documents and nondocumentary verification your institution will require. If you merely use a public database to determine that this business and these signers are who they say they are, that is nondocumentary verification. If you download actual documents, that is documentary verification.
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Learn more about Deborah's webinar Opening Entity Accounts (updated for the new CDD rules)
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