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#2285790 - 06/22/23 05:56 PM CIP for lending
Secret Squirrel Offline
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Joined: Jun 2017
Posts: 33
If we have a mortgage loan and there is a party that is "Title Only" not on the loan should/would you ask for CIP information on the "Title Only" party?

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#2285792 - 06/22/23 06:06 PM Re: CIP for lending Secret Squirrel
rlcarey Offline
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Galveston, TX
If all they are going to do is sign a deed of trust/mortgage, they are not a customer.
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#2285827 - 06/23/23 12:31 PM Re: CIP for lending Secret Squirrel
edAudit Offline
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edAudit
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You are here
While they are not customers for CIP. They have ownership rights (of some sort) to property that you are giving a mortgage to. From an operational standpoint, would you want to know who this person is?
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#2285845 - 06/23/23 01:38 PM Re: CIP for lending Secret Squirrel
John Burnett Offline
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John Burnett
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Cape Cod
A great example of when "KYC" is not only the minimum that regulations require.
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#2285874 - 06/23/23 04:44 PM Re: CIP for lending Secret Squirrel
rlcarey Offline
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rlcarey
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Galveston, TX
Well, I was not insinuating that you would not want to identity the signer on the deed of trust, but the title company would most likely do that. But the bank has no CIP or CIP retention requirements. That does not mean you do not exercise common sense.
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#2285910 - 06/23/23 09:48 PM Re: CIP for lending Secret Squirrel
Andy_Z Offline
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Should you know, that's a good idea. Should you go beyond the requirements, that's up to you but other than knowing who that person is, what does it impact?

I make a loan to Randy on a home and bring in that Note/receivable to pledge as collateral on a loan to me. Does it matter to your bank that the home is/is not in a flood area? It should, but you are not responsible to know that or if there is flood insurance.

I guess there are things you ought to know, but do you have to, and are they citable if you don't, No. Document the file for future use and move on without creating work.
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