Who to CIP on a POA

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Question:

If an attorney-in-fact comes in with a power of attorney and wants to open an account on behalf of the principal without the principal being present, who do we CIP?

Answer:

If the principal isn’t there because he is incapacitated or incompetent (and the POA is still in force because it is a durable POA), then you have a situation where an individual is opening an account on behalf of an individual who lacks capacity. Under the CIP rules, in that case, you CIP the AIF. If the principal is merely unavailable, you have to CIP the principal because the special circumstance referred to earlier in this answer will not apply.
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