12/09/2018
When opening accounts for the City (Police, Fire Department, etc.) what documents are we required to collect? Here is why I ask:
“Earlier this week the city of XYZ opened a new savings account. They have been a customer since 1977, therefore we don’t have all the paperwork that is now required. This account was brought in by the Chief of Police and the Warrant Officer saying that it needed to be a new account under the “CIF” of the City of XYZ, but needed to be worded titled “The State of TX vs ….. defendant.” There has been an account like this in the past, the defendant is in jail and it's confiscated funds. My question is, what all documents do we need?”
11/25/2018
I have a new customer who has a single member entity that is disregarded for tax purposes (rental income and expenses are reported on personal tax return), but has been assigned an EIN separate from his SSN. The entity is 12 years old and he has misplaced his letter from the IRS verifying the LLC's EIN. What is the easiest way to document this to comply with CIP procedures? Can I take his and his accountant's word that the EIN is correct?
11/11/2018
Would a student identification card be an appropriate ID for a minor account if they dont have a drivers license or state ID? The parent/guardian is on the account with them and we do have sufficient ID for them.
09/30/2018
We have recently acquired two branches of another bank, along with the customers base from those two locations. We are wondering about the CIP violations that we seemed to have "inherited" from these two locations. Are these now our issues or does it fall under the bank of account opening? We are the second bank to own these two particular locations. Any information or guidance is appreciated.
09/09/2018
Where can I find regulatory citation regarding the retention of copy of driver's license from CIP process on a loan application? Is it okay to retain in loan file or separate CIP file? Our concern is possible fair lending implications.
09/09/2018
Do Patriot Act Notices and UBO notices have to be on the bank website? We do not open accounts online at this time.
08/19/2018
We are looking at revising signature cards for an existing HOA management company and their subsidiaries. We are adding an employee and deleting an employee. If the employee is just an authorized signer and not an owner or person in control, do we need to gather or require the beneficial ownership certification?
This relationship was created before the regulation went into effect. We have nothing on file regarding beneficial ownership and are wondering if this would be a “triggering event”?
04/15/2018
In regards to the control prong of the beneficial ownership certification, can more than one person be listed? We have condominium association accounts that have a board that makes all decisions and they may not want to designate just one control person.
04/08/2018
Does the beneficial ownership rule apply to DBA's (fictitious name registered with the Secretary of State)?
03/18/2018
My inquiry has to do with CIP requirements regarding opening an account under a FLUTMA (we are in Florida). The account holder which is the grandmother opened an account under a FLUTMA for the grandchild. The parents do not wish to release a copy of their child's birth certificate due to possible fears of compromise. Is it mandatory to require CIP information on the minor once the Chex Systems clearance has been obtained; is a birth certificate actually required?