Answer:
Answer by John Burnett:
The absolutely accurate answer is that we don't yet know what the enhanced ID requirements will be.
However, it's likely that we will be required to know more about the ID of each signer on the accounts. And we will probably have to check each name against OFAC and Control Lists.
Just how far we will have to go is a good question. For instance, suppose that the business is a corporation, and it's Board has voted to authorize the treasurer and/or assistant treasurer to open and maintain banking accounts. No other officers are listed in the corporate resolution.
Will we still want to know something about the other officers of the corporation? Who they are and whether they appear on the "Lists"?
Answer:
Answer by Dana Tuner:
One of the best suggestions -- and one that likely won't be included in regulations -- is to include each signer's thumbprint on the signature card. Many institutions have redesigned their signature cards, loan and employment applications, and receipts to accommodate this feature. The employee who collects the account or employment application then becomes a witness to the transaction -- and he/she may testify and introduce the item in court, if it's necessary.
Answer:
Answer by Ken Golliher:
John is right, the "details" will be in the regulations. If they are to be final in October, we need to see a proposal pretty soon.
My suggestion for an advance "peek" is to review the OCC examination procedures. It is doubtful that Treasury will require less than one of its subsidiaries already recommends...those procedures suggest that business signatories be identified.
First published on BankersOnline.com 5/20/02
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