07/04/2011
Is each institution required to develop its own CIP tailored to its product offerings customer base and geographic location?
06/20/2011
CIP requires the bank to verify the information that the customer has supplied. We verify the information using ChexSystems. Is that sufficient for verifying the address or are we required to mail something like a “Thank You Note”?
04/25/2011
During one of our recent exams, it was suggested by the examiners that we open accounts online (which surprised us); they would like us to phase out our brokered deposits and felt we could replace these deposits by opening accounts online. I have been trying to gather some information on what is involved in opening accounts online, in particular the risks involved; how to handle CIP, how to handle disclosures and how to obtain the initial deposit. I put out a question on Banker Threads, but did not receive much information. Can you direct me to any information that would help?Also, our president would like me to do a comparison to Free Checking - the pros and cons vs online accounts. While I have not experienced opening accounts online, I have been at a bank (some years ago) that offered free checking and we had a good experience. Few losses, customers really liked not having to worry about a maintenance fee, and the average balance tended to be around $3,000. I was wondering if you could direct me to any other sources that might be able to provide information or statistics on free checking?
04/11/2011
We have a customer that has a representative payee on his account and has his SSI direct deposited. The rep payee has died. The customer has a new payee appointed to his funds through Social Security and has brought the paperwork to us where he has made the change. We are not changing ownership of the account just changing payee names. Would you close the account out or have the new payee sign a name change form or how would you handle this?
02/14/2011
We have a number of Amish people wanting to open accounts with us. Under the required CIP the Amish don't have a government issued or other photo ID because of their religion. What may we use?
01/31/2011
When a trust department is involved in administration of corporate trusts, what is the CIP requirement for the municipality? For example, a corporate trust department administers the various accounts related to a municipality's bond issue for sewer and water. Do the authorized signers for the municipality need to be subject to CIP, since they are essentially “in control” of the funds?
01/24/2011
CIP requires customers to have a physical address on record. I believe CTRs also require a physical address to be reported. What if a customer changes their address to a PO Box and doesn't provide a physical address? Must the account be closed? Should mailings stop until the physical address is supplied? Any other thoughts?
01/24/2011
I am opening a guardianship account. Do I need IDs from the owner (ward) or just the guardians. I do have the court papers.
11/01/2010
Can an authorized individual of a major, publicly-traded stock company ever be exempted from CIP requirements when opening a deposit account at a bank?
10/11/2010
We have completed our CIP on the customer opening the account as a DBA, would we still need to complete a CIP on their business? If so how would we do that?