We have a new business customer who is opening an account with two signers. One is a local person, the other is abroad permanently. What would be the proper way to conduct CIP on a person abroad?
When a trust department is involved in administration of corporate trusts, what is the CIP requirement for the municipality? For example, a corporate trust department administers the various accounts related to a municipality's bond issue for sewer and water. Do the authorized signers for the municipality need to be subject to CIP, since they are essentially “in control” of the funds?
We have a request from a company's board member to review the signature card of the company of which he is a board member; however he is not a signer on the account. As a board member, does he have a right to review the signature card?
When the owner of a DBA dies, are the authorized signers still authorized to sign? The account uses the deceased owner's social security number.
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 a customer deposits $8,000 cash into his or her personal account and $3,000 cash into a business account for which he or she is an authorized signer, does a CTR need to be filled out? What if the customer makes the $8,000 deposit into his or her personal account and one of the other authorized signers on the business account makes the $3,000 deposit, then does a CTR need to be filled out?
I am currently doing the annual review of Phase II exempted entities and I found that a previously exempted business account is now conducting cash deposits to a different account, opened in September, 2006, with a different TIN. The names on the accounts are the same and two of four authorized signers are on both accounts. Can I exempt the new TIN because of the existing exemption status for the old TIN, or do I have to wait for September, 2007?
Are financial institutions required to obtain CIP information from authorized signers on municipal accounts?
When opening a new business account, also a new bank relationship, are we required to get the authorized signer's social security number if the person refuses to give it to us? Does the Patriot Act apply to this at all?
We have an account holder who is adding an authorized signer to their account. Do we need to perform a CIP on the authorized signer?