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Who is Exempt from CIP Requirements?

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Can an authorized individual of a major, publicly-traded stock company ever be exempted from CIP requirements when opening a deposit account at a bank?

If the account is being opened in the name of the individual, the answer is no. If the account is being opened in the name of a listed company (as defined in the CTR exemption regulations), the listed company is an exception to the definition of "customer" in the CIP regulation, and would not have to be run through a bank's CIP process. An authorized signer on that company would similarly not need to be run through a bank's CIP process under the regulatory requirements.

A bank's CIP may provide for CIP requirements for even listed companies and for their authorized signers, but understand that that is a bank policy requirement, not a regulatory requirement. The bank could just as easily exclude listed companies and their account signers from its CIP policy, and be compliant with the CIP regulations.

First published on 11/01/10

First published on 11/01/2010

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