Wire Sent Via Public Fund Deposit Program

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Question:

If money is wired into a bank to purchase a CD through the Public Fund Deposit Program, is the customer exempt from the CIP requirements of the USA Patriot Act? I have been told that he/she would be exempt, but I would like to have proof that this is true.

Answer:

If these are public funds, CIP regulations indicate that a customer does not include a person described in Section 103.22(d)(2)(ii)-(iv), but it will all come down to the receiving bank's board-approved CIP policies.

First published on BankersOnline.com 2/22/10