10/04/2010
In the past, we have allowed grandparents to open savings accounts for their grandchildren with the grandchildren being the primary owners and the grandparents as secondary. They would have the child's social security number. They would sign the child's name,(child is unable to sign due to age). Relative to CIP purposes can this still be done?
10/04/2010
I'm trying to figure out if CIP is required on the merchants for whom we process ACH transactions. Here's the scenario. Company A (Merchants) sells goods/services on the internet. They send their debit and credit transactions to Company B (Payment Processor), who then in turn sends their ACH files to us for processing through their account(the merchants does not have an account with us). We perform all BSA requirements for the processor because they are our customer, but I am wondering if the merchant is considered our customer as well, or just a customer of the Payment Processor? Should we be obtaining CIP information on the merchants?
08/30/2010
I have been in banking for awhile and am being told I am making a mountain out of a mole hill. When it comes to DBA accounts, I have one opinion on what purpose/style account should be opened and I am being told by others that I am not correct. There are two differing opinions when we open a DBA account. For example, one opinion is that Mickey Mouse DBA Great Escape Mousetraps should be opened as a personal style account, where at the account maintenance level, the code would indicate consumer for the purpose of household or personal use. The other opinion is one in which it should opened as a business style account, where at the account maintenance level, the code would indicate business for the purpose of business. The reporting tax ID number in both situations would be the customer’s Social Security Number. If I understand correctly, there are different regulations regarding the purpose/style of an account and there are different protections and benefits for each purpose/style. Can you please help as to which purpose/style would be proper? My best interest is doing things the correct way for the both the bank and the customer.
06/21/2010
When obtaining identification from new account holders, sometimes the address is different than the current address they are giving us. How can we validate that the current address is correct, and what documentation should we expect them to have to support the new address?
06/07/2010
We had a customer present an ID for our CIP (new account) procedure and it was expired. It was still the person opening the new account, but our security officer had a major problem. Why is this a big deal?
05/24/2010
Other than a signature card, are we required to get any other legal documents when opening a representative payee account for an adult?
04/26/2010
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.
04/12/2010
We have a customer who has titled his business as an investment company, and indicated that on his CIP form. Recently, he withdrew $15,000 in cash, and when asked the nature of his business, explained that it was "hard-money lending". Considering the amount of cash withdrawn, which is unusual for him, could he be an MSB? What is a hard-money lender?
04/05/2010
Do we need to CIP and OFAC non-customers if we sell them money orders?
03/29/2010
For purposes of setting up an estate account, who is considered the customer for purposes of CIP?