02/22/2010
If money is wired into a bank to purchase a CD through the Public Fund Deposit Program, is the customer exempt from the CIP requirements of the USA Patriot Act? I have been told that he/she would be exempt, but I would like to have proof that this is true.
02/01/2010
It is my understanding that FinCEN put out a ruling on CIP address confidentiality programs (ACP). Where can I find this ruling?
01/18/2010
We have been getting a lot of Foreign Private Investment Companies opening accounts at our bank. We are struggling with the address verifications for them.What type of documents are used to verify addresses? Would a letter from an attorney or accountant from the country that would state the PICs' address suffice? Would the address shown on the articles suffice?
01/04/2010
If a non-customer purchases a savings bond at our bank do we need to CIP the person?
11/30/2009
We have a person who wants to open a checking account. She gave us a Mexican Passport and a credit card as ID. She has a Social Security card. We asked her if she has any US ID and she gave us a US Visa that is valid for one year. Can we open the account for her?
11/30/2009
We have a customer who has documentation to support that he is a non-resident alien, however he meets the substantial presence test and has a "For work purpose only" social security card. Would this customer be considered a resident or non-resident alien for bank purposes, and can we use the social security card for CIP documentation?
11/23/2009
We have a payment processor who has a relationship with an ISO who procures new merchant relationships for him. The merchants do not have accounts with us, but because we process their ach transactions through our payment processor, does that make them our customer as far as CIP?
11/16/2009
Can a partnership report under one of the partner’s social security number, rather than filing for a EIN?
11/16/2009
Our bank is second in a participation loan. Do we have to obtain identification and CIPs for the guarantors?
11/16/2009
We have a payment processor who has a relationship with an ISO who procures new merchant relationships for them. The merchants do not have accounts with us, but because we process their ach transactions through our payment processor, does that make them our customer as far as CIP?