Our bank holding company owns an insurance agency and a brokerage office which are both located in the bank. I am not sure how they fit into CIP. Are they covered? If they are can the bank perform their 326 requirements for them?

So far, insurance companies & brokerages are NOT covered. See the definition of "bank" in §103.121(a)(2).

Insurance companies are covered by 326, but do not have regs issued as yet. If by "brokerage" you mean securities brokers/dealers, their regs came out on the same day as the ones for depository institutions. See: http://www.fincen.gov/326bdfinal.pdf

Thanks for the clarification Ted.

I agree with Ted and note that, since the insurance agency appears to be a subsidiary, it is covered by the bank's BSA and CIP programs until such time as specific insurance industry regulations are issued.

Wait a minute, Ken. Are you saying that if the Insurance Co. and bank are in the same holding company, that the Ins Co must play by the Bank's CIP rules? Is it only if the Ins Co is a department of the bank (Same TIN)? Please clarify.

As noted, only if the insurance company is a subsidiary of the bank would I say it is subject to the bank's BSA/CIP program.

Excuse me, just re-read the question. Anon indicated the insurance company is owned by the holding company, thus it is not a subsidiary of the bank. It is subject to CIP when insurance industry regs are issued, not before.

Whew! That's what I was thinking Ken. Glad to see your clarification.