03/02/2009
Who is the customer for CIP purposes on an IOLTA account and how should the account be styled?
02/16/2009
We have a customer who was with us before all the CIP requirements, and they are doing something to their accounts that requires a new signature card. Do we have to get updated CIP information? I know it’s good practice and I already advised it, but I was wondering if there was a compliance requirement to get the information in this case.
02/09/2009
What would my bank's responsibility be for Patriot Act and OFAC compliance if we purchased a block of loans from another bank? Can we rely on the information gathered in the loan file or would it be best practice to run OFAC again?
02/02/2009
We normally take a copy of the driver's license of a new commercial borrower and put in the file for CIP purposes. We are now being told that we need to complete a CIP verification checklist and have that in the file also. Is the checklist necessary and if so, can you direct me to the regulation?
01/19/2009
Do the same CIP rules and procedures apply to IRAs and HSAs?
01/12/2009
Is CIP documentation required for court ordered accounts such as when minor children receive money from a sale of property and the court orders CDs to be purchased for the minors and held until they are 18 years old?
11/17/2008
Are government agents or law enforcement employees exempt from providing their personal information for CIP when they open accounts?
11/10/2008
Does the Patriot Act require that national banks update existing customers and merged customer CIP information? Do we have to update customers with a P.O. Box as their physical address if they have had their accounts with the bank since before the Patriot Act was written or were customers with a merged bank?
11/03/2008
What is the proper titling for a representative payee account for Social Security and what would the relationships be?
10/01/2008
Date of ?Initial Detection? and the 30-Day SAR Clock By FinCEN Office of Outreach Resources