Do We CIP Minors?

Question:

At what age must we do CIP on a person if they are a minor or is it required? We require all minor accounts to have someone over 18 as a signer and do CIP on them. For instance, if a parent opens a savings account for a 10-year-old child, are we required to do CIP on the child? At what age is a child considered legally competent?

Answer:

Generally, a minor becomes an adult according to state law at age 18. If you establish an account where a child is the customer the CIP regulations apply regardless of the child's age. The regulations do allow that when an account is opened by an adult who is acting on behalf of a child; e.g. under a UTMA, you should treat the adult as the customer.

Any distinctions you wish to make regarding the treatment of minors for identification purposes should be spelled out in your CIP. If you do not establish lesser standards there, your bank must treat minors the same way you treat adults.

First published on BankersOnline.com 1/2/06