Are most banks writing into their CIP policy that signatories on entity accounts will be put through the CIP process? This policy gets deeper and deeper as I go. I don't want to be questioned by examiners, but I also want the policy workable. What is your bank doing?

The regulation does not require that you obtain/verify ID information on signatories. However, there may be a reason that you will want to do so. Ken Golliher points out that "documentary" verification for entities is subject to relatively easy fraud, and suggests that checking out the principals might be a good idea.

Think about what your commercial lenders do for small businesses. They normally require personal guarantees of the principals on the smaller borrowers. They also take time to know who the principals are, since it's really the integrity of the business's principals that the bank needs to count on (in addition to cash flow and the rest of the basics).

So you might want to include collection and verification of signatory ID info in your CIP. And you'll describe the limited circumstance when this will be done. But you can count on examiners to "ding" you if you say you'll do it and you fail to.

D Timberlake: Look at subsection (b)(2)(ii)(C) of the regulation. It indicates that: "The CIP must address situations where, based on the bank's risk assessment of a new account opened by a customer that is not an individual, the bank will obtain information about individuals with authority or control over such account, including signatories, in order to verify the customer's identity. This verification method applies only when the bank cannot verify the customer’s true identity...". So your CIP must address the issue, based upon your risk assessment of that account.

We are extened our CIP policy to signers on business accounts. We have always required that most of the information in CIP guidelines be obtained for signers.

We establish a CIF file on our system for account signers (with the single exception of our correspondent bank account signers). We also plan to continue our current procedure to document identity of nonpersonal account signers.