Info Required on Phase 1 Exemptions

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Question:

On a Phase 1 exemption, are we required to get the personal information on each of the signers, such as address, social security number, DOB and drivers license? I was under the impression that we were not able to ask for this information because of the Phase 1 status.

Answer:

I think you are confusing Phase I exemptions and CIP requirements. Any requirements imposed on entities that are exempt from the definition of customer in the CIP regulation are purely left up to the bank.

First published on BankersOnline.com 4/26/10