I'm still confused about credit cards regarding the customer relationship (when is the applicant a customer of the bank or the customer of a third-party?) In cases where a community bank has applications in their lobbies that directs them to a credit card vendor or another financial institution for underwriting and processing, who is ultimately responsible for assuring the identity, verification, and record retention? In other word, under whose CIP does the customer fall? Does the determination of who has the customer relationship rest with who services the cards? Who underwrites the card? Whose name is on the card? Who realizes the income/loss? Who carries it on the balance sheet? Etc. Your advice, guidance, and reasoning would be very much appreciated.