03/03/2024
We continue to have issues collecting customers current physical addresses when opening new accounts. Our frontline thinks they find loopholes in our policy, deviating from the intent of the policy, and they create larger problems.
Is it permissible to have a policy or procedure in place for changing the address on a new account for a new customer within 30 days of the date opened? Say if a customer opens an account on the 10th and then comes in on 21st to change their address, do other banks have a policy to collect a proof of address at this time since it is a new account?
09/03/2023
If we have a revocable living trust, and the Grantor and Trustee are different, would we CIP both the Trustee and
Grantor, or just the Trustee?
03/12/2023
For loans that take months from application to closing, at what point would you recommend collecting updated Customer Due Diligence? My initial thought is that as long as the loan had not closed, we can rely on the information from the previous 90 days, but would want to verify/update after that period, and I am having difficulty finding guidance on specific timing.
08/28/2022
If an LLC is doing business under a trade name such as "ABC LLC dba John's Farm Supplies," what is needed for beneficial ownership?
I know the ABC LLC is required to have beneficial ownership and control prong information, but what about the dba John's Farm Supplies, does it need anything separate?
10/17/2021
If a customer presents a military identification card and has no other form of ID, it is my understanding is you cannot make a copy of Military ID's. What other forms can be used? This person does not drive and has no transportation to get to the DMV. He does have an expired TX DL but that is all.
10/17/2021
How are smaller banks, say in the $200M asset size, managing compliance risk when diving into online account opening? I'm very concerned about CIP-CDD-EDD. I cannot fathom never obtaining a wet signature or seeing a check prior to accepting a deposit. Also, asking the CDD-EDD questions online is completely different than in person regarding getting a feel for the customer. Do most banks also open new accounts online for businesses, trusts, estates, etc? Is there a vetted software company that is preferred for this endeavor?
05/16/2021
What does "Social Security number issued for randomized issuance:N" mean? In the past I have only seen "Social Security number issued for randomized issuance:Y...."
Is there a place where we can see a description of all response codes for Chex Systems?
05/09/2021
We provide services non-account holders, as well as account holders. Our platforms require the creation of customer "folders" for all teller transactions. This means we capture CIP elements to create non-account holder folders to process those transactions.
As the USA PATRIOT Act requires the capturing of CIP elements for account opening only (as far as I understand), are we also required to post customer CIP notices at the teller stations as well for non-account holders? Logic would dictate that the answer is yes, because the same CIP information is being collected for both groups, and we practice our KYC and AML principles for both. (Non-account holders or "consumers" can launder money or finance terrorism just as easily, or more easily, as an account holder.)
However, the PATRIOT Act only requires the notices for account opening activities/locations. Technicality, I'm sure. But what is the right thing to do?
10/04/2020
In the August 30, 2020, Weekly Banker Briefing there was a question regarding receiving scanned driver's licenses when customers open accounts online. The last sentence of the response said the financial institution must delete the copy or image after use. I don't see that in section 213 of the Economic Growth, Regulatory Relief and Consumer Protection Act. Where can I find information regarding the requirement to delete the image?
https://www.bankersonline.com/qa/scanned-drivers-licenses-it-legal
08/09/2020
Regarding a Beneficial Owner Certification: ABC, LLC (Borrower) is 100% owned by DEF, Inc. DEF, Inc. is 33.33% owned by 3 individuals. Would I need to list the individuals as having 25% or more ownership on the certification, even though they are not owners of ABC, LLC?