A question on who is considered a customer for purposes of the customer identification program (CIP) regulation -- convenience signers, safe deposit box signers or account beneficiaries is answered. The BSA/AML Examination Manual provides more in-depth guidance on the types of accounts and customers/members subject to the CIP regulation. The exam manual goes on to state that the CIP rule applies to a "customer." Although authorized signers are not considered customers by the CIP regulations at 31 CFR 103.121, you have to know what your own institution's board-approved CIP has to say on the subject. If your policy calls for completing CIP on such individuals, you have to do it.
Who Is Considered a Customer for Cip Purposes?
Question: Who is considered a "customer" for purposes of the customer identification program regulation - convenience signers, safe deposit box signers or account beneficiari...