Answer:
Answer by Brian Crow:Since you have to identify business customers as well as consumer customers to meet your CIP requirements, you should already be collecting business identification in the form of articles of incorporations, LLC agreeements, partnership agreements, assumed name certificates, etc. Utilize these identifying documents when completing the new CTR for a business.
Answer:
Answer by Ken Golliher: The instructions are pretty clear, but I've added emphasis in a couple places:
Item *20 Form of identification: Enter in Item 20 the information used to identify the individual or entity recorded in Item 4. Check box 20b if the identification was a driver's license or state ID, box 20c if the identification was a passport or box 20d if the identification was an alien registration. Check box 20z if a different identification was provided and describe that identification in the "Other" text field. "Other" identification could include such things as an entity's business license or incorporation documents, corporate ID cards, local government ID cards, etc. [Abridged]
As noted, this is information that the CIP regulation required your bank to obtain if the account was opened in the last 9 years. The Form 112 is simply repurposing information you should already have.
The current version of the Examination Manual was published in April, 2010. It is not a reliable resource for anything that has changed since that date.
First published on BankersOnline.com 2/18/13
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