Answer:
Although authorized signers are not considered customers by the CIP regulations at 31 CFR 103.121, you have to know what your own institution's board-approved CIP has to say on the subject. If your policy calls for completing CIP on such individuals, you have to do it.
At BankersOnline's BSA Top Gun Conference held in late February, 2007, we used an audience response system to gather data from the attendees about various questions. Two questions we asked related to CIPing authorized signers and guarantors. As noted earlier, the CIP rules do not require an institution to CIP authorized signers and guarantors. That is left up to each institution’s individual CIP. An astonishing 65% of those surveyed at the BOL BSA Top Gun conference said they DO CIP authorized signers and guarantors. When asked what they require from them, they said "All components -- same information they require from account owners."
First published on BankersOnline.com 4/23/07
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