We have a business who is acting as an Escrow Agent on a piece of property for 6 individuals are in negotations to buy. These 6 individuals do not have a partnership agreement--One individual is from NY, 2 from TX, and 2 from TX which are trutees. Under the CIP regulation are we required to collect CIP information on all individuals which will be beneficiaries on this account? Or is it sufficent to just collect on one of the beneficiaries?

I would CIP the Escrow agent it is his account, not the Beneficiaries.

Not that familiar with New Jersey, but I would assume that this "business" is properly licensed to act as an escrow agent, if required.

Yes, they are licensed to act as an escrow agent but since the 6 individuals aren't in a partnership wanted to know what our obligation is relating to CIP and who we would want to collect info on. The escrow agent? The 6 individuals? The escrow agent & one beneficiary, or all involved?

You must CIP the account owner - the escrow agent. Your board approved CIP policy may require additional due diligence on the beneficiaries, but that is an internal policy issue as opposed to a regulatory requirement.

Not that you wouldn't just believe everything Brenda says (I do), but this is from the supplementary information that accompanied the final CIP regulation:

For purposes of this rule, a bank will not be required to look through trust, escrow, or similar accounts to verify the identities of beneficiaries and instead will only be required to verify the identity of the named accountholder.

There's a footnote that, more or less, says your risk assessment of the customer could prompt you to "look through" the account and identify the beneficial owners.