New Account, POA, and CIP

Question: We've been asked by a long standing customer to open an account for him so that he can serve as a representative payee for his mother, who is living in another state. She is not available. We have no ID for her, and although he has power of attorney papers, we have nothing for documentation on the account except the letter from the Social Security Administration. Our CIP says without documentation, or verified identification, we can't open the account. So one government agency says to open the account and the other says we can't. I think our front line did the right thing in turning down his request for the account in accordance with our CIP rules, but now we have a very irate customer on our hands - and he's a long standing, good customer. What do we need to do?

Answer: You need to amend your CIP. You will find situations where you are instructed by the court to open an account, or, as in your instance, by the Social Security Administration. Under "exceptions" in your CIP, you need to note something to the effect that "...in the case of court orders, or authority from a government agency, the order or authorization will be considered to be sufficient documentation to open the account. The original or a certified copy of such order or authorization must be maintained on file."

Copyright © 2004 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 13, No. 12, 2/04