CIP: Identity Verification & Compliance Flashcards
What exactly is CIP, and what does it accomplish?
Customer Identification Program; allows institutions to form a reasonable belief that it knows the true identity of each new customer.
What will happen if my bank and I do not follow minimum CIP requirements?
Failing to adhere to mandatory CIP program requirements could generate large substantial fines to you and your bank, prison time, and/or a take over of your bank by your regulator
Which acts is CIP associated with?
The Bank Secrecy Act (BSA) and the USA Patriot Act of 2001; is specific for each institution, not a one size fits all program
Are recording references in line with CIP?
No, a person’s information and identification must always be verified by the institution’s CIP.
Following your institution’s CIP rules allows you to prevent which activities?
- Illegal Gambling
- Terrorist Activities
- Drug Dealing
- Tax Evasion
- Elder Theft
- Money Laundering
- Prostitution
- Bootlegging
When was CIP created?
in October 2001, following 9/11/01, when President Bush signed the USA Patriot Act
What are the requirements of CIP?
CIP rules state that your institution must document the procedures which will be followed when opening account. The procedures must specify the identifying information that will be obtained from each customer; CIP is not a one size fits all program; each institution must develop their own plan
Which four piece of identifying information must be obtained?
- Name
- Date of Birth
- Street Address
- Identification Number
Individual Name data includes:
the individual’s legal name and potentially a DBA name
Individual Date of Birth data includes:
the actual DoB; age is not sufficient
Individual Address data includes:
- a residential or business street address
- in the case of members of the military, Army Post Office (APO) or Fleet Post Office (FPA) are acceptable
- for people w/o residential addresses, a residential or business address of next of kin or a contact individual is necessary
Individual Identification Number data includes:
- a SSN (resident alien)
- a passport number and country of issuance
- an alien ID card (green card)
- a number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard
Corporation Name data includes:
legal name of the entity or DBA name
Corporation Identification Number data includes:
- Employer Identification Number (EIN) for a US person
- A Taxpayer ID Number (TIN)/EIN or alternate gvmt issued documentation certifying the existence of the business or enterprise for a non-US person
Corporation Address data includes:
the address of the entity’s principal place of business, local office, or other physical location and any other mailing addresses
Corporation Authority Figure Data:
information on Corporation Authority Figures is institution specific; check with supervisor to determine what NMSB requires
Corporation Beneficial Owner data:
only applicable at the time of account opening; may rely on the customer to state who its beneficial owners are
Who in the institution has the authority to waive any of the minimum CIP information requirements of the USA Patriot Act and its implementing regulation?
Nobody
What are the two CIP exception categories?
- Persons applying for a TIN
2. Credit card accounts
How can an institutions CIP accommodate the TIN exception?
- by examination of a copy of the TIN application
- by making a copy of the TIN application
- by having the customer sign an “awaiting TIN” certification
How can an institutions CIP accommodate the Credit Card exception?
- by acquiring necessary identifying information from a trusted third-party
What type of documents can be collected for an individual?
unexpired government photo ID (Driver’s License, passport, green card); limited use of utility and credit card bills
What type of documents can be collected for a person other than an individual?
certified Articles of Incorporation, a government-issued license, a partnership agreement or a trust instrument; the bank may rely on photocopies or other reproductions
What Non-documentary ID methods are acceptable?
- contact the customer directly
- Verify information provided by customer with a consumer-reporting agency
- check references with prior financial institutions (do not use institution contact info provided by the customer)
- Obtain a financial statement