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Verify Both Buyers and Sellers for CIP?

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Our bank does servicing of "Contracts for Deed." This is where a buyer and seller enter into a contract for deed between themselves, the bank receives the payment from the buyer and disburses it to the seller. My question is, are we required to verify both buyers and sellers for CIP?

In its essence, holding a contract for deed is an escrow arrangement where the bank is the escrow agent. Your customer is the seller of the property, that's whose identity you need to establish. However, if you do the information reporting you will need the purchaser's identifying information for the IRS.

First published on 8/28/06

First published on 08/28/2006

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