Let me ask a stupid question . Are you all including NDIP (non-deposit investment products) in your CIP programs? I am assuming that we have to.

We just sold ours off. But if they meet the definition of being your "customer" I would include them.

I plan to include our subsidiary broker/dealer in CIP procedures and processes.

Our NDIP is different. We have dual employees but all products sold are through a brokerge firm. I've been told they are going to have their own CIP program since they aren't bank products.

See, ours are dual employees, too. So the question then becomes, are both the bank and broker/dealer required to have CIP programs?

In my post above, I specifically stated "your customer". I believe you would need a CIP on the customer depending on the hat you are wearing. I see this as being a clean method of addressing which entity is serving the customer.