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#87663 - 06/12/03 04:39 PM CIP & pledging Collateral
Anonymous
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If a person is pledging collateral for a loan but is not a borrower to that loan, do we need to comply with CIP for that person??

they do not sign for the account only for the pledge

any help would be appreciated

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#87664 - 06/12/03 04:43 PM Re: CIP & pledging Collateral
Andy_Z Offline
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Without researching this new topic I'd say they either already have a continuing relationship with you (such as a CD at your bank pledged) and CIP is done, or you do not have one already and this would not constitute a relationship either as they are not your customer, meaning CIP doesn't apply.
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#87665 - 06/12/03 07:32 PM Re: CIP & pledging Collateral
SMQ, CRCM Offline
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Thanks Andy, this was my thought also. But-----I feel so much better hearing it from you.

What about signers on corp. accounts? We do ID the corp., but are we "required" to ID the signers? Granted, may be good to do, but is it required by reg?
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#87666 - 06/12/03 07:35 PM Re: CIP & pledging Collateral
Elwood P. Dowd Offline
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No, verifying the identity of an entity's signatories is not required by the regulation. It is mentioned as a possible fall back position if you are unable to verify the identity of the entity.
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