04/04/2005
CIP question: We are having issues with exactly the intent of the "verification documentation." Should the documents we require for verification verify each of the four big items; or does the verification simply prove to us that we are dealing with the correct person and that we can rely on the 4 items they gave us?
04/04/2005
I have been all through BOL looking for an answer to this question. For CIP purposes, on a consumer account, if the customer as defined in the reg wants to add a signer must we solicit identity information and complete verification procedures? I believe that based on the reg it would be governed by our CIP policy and the signer would not be considered a customer.
04/01/2005
Question: We're a new bank that just opened in a community with a large Amish population.
04/01/2005
By John Byrne, representing the American Bankers Association, and Robert Rowe, representing the Independent Community Bankers of America (ICBA), to the Bank Secrecy Act Advisory Group
03/21/2005
A customer came in and opened a savings account for his disabled son. He is the son's representative payee. Due to the USA Patriot Act (CIP) do we need to get ID from the son? How should the account be titled? Is the son the beneficiary? Can we offer a MAC card on this account?
02/07/2005
After a recent exam, our institution had an informal recommendation to address procedures for addressing gov't requests for information (separate from OFAC and 314a) in our CIP Program. Any help on what is this informal recommendation should include?
01/31/2005
Are Native American Casinos and individuals subject to CIP requirements?
01/17/2005
I have been told that the employees in charge of on-line banking are considering allowing wire transfers through our new on-line banking product. What kind of compliance and security issues should they consider when they are designing this product? We are new to on-line banking so my feeling is that we should learn to crawl before we run. Some of the bigger banks do not have this on-line banking feature. How does our midsize bank think they have the resources and the knowledge to accomplish this?
01/01/2005
What Does The Bank Protection Act Really Mean?
11/29/2004
Is it a current rule within the USA PATRIOT Act that our CIP require a social security number for non business, non interest bearing accounts? I have read section 326, but it's unclear to me that this proposal was actually passed.