Without Prejudice.
This concerns
the final rule concerning Customer Identification Programs for U.S. banks in light of the Patriot 4ct. Some of the points are nothing new at all.
Concerning the final rule concerning CIP (this is based on information from the
US Treasury themselves!):
1) Do the CIP final rules require photo ID? Photo Identification is not required under CIP. "A photo or similar safeguard" is called for--a signature, an autograph, a thumbprint, a fingerprint or the like, initials, a seal or stamp might suffice as "similar safeguard". Also if the account is being opened for a corporation, trust or the like then the photo ID might be a ID card for the company identifying someone as authorized representative. Accounts are opened for persons/organizations therefore I guess a photograph might identify a representative or an agent or something?
2) Do the CIP rules require some kind of identifying number? Based on report by the U.S. Department of the Treasury, an identifying number of some sort is required for the customer.
3) Do CIP rules apply to check cashing or wire transfer? An "account" does not include and therefore CIP does not apply to: cashing checks, wire transfers, selling checks of money orders, accounts acquired through bank M&A, accounts for certain employee benefit plans (EIRA Act) because provision of such services is not to "customers". That is those who a U.S. bank provides such services to *ARE NOT* customers and are not subject to CIP.
4) Is my driver license or passport good enough to open an account for a trust or corporation? This is not anything new but if you are applying for a bank account on behalf of or for a trust or corporation,
the customer is the trust or corporation not you. The identifying number for a corporation might be its charter number, registration number of file number or it FEIN. If for a driver-person then the DL #.
5) Do all the signatories on an account have to have taxpayer identifying numbers? Signatories on an account are not necessarily the customer or owner of an bank account and therefore identifying numbers are not necessarily required for signatories on accounts.
6) How long does a bank have to keep copies of identification documents? Banks are not required under CIP rules to keep copies of identification used to open accounts (as per burden reduction and Paperwork Reduction Act).
7) Is a date of birth required for opening a bank account? Date of birth is for "individuals". An account opened for a trust or company requires the details of the customer NOT the signatory or agent.
8) If I live in an RV can I use a PO box for opening bank account? AFO or FPO is OK for addresses. "PO Boxes are apparently no-go". For individuals address of next of kin or other contact person is OK. For organizations physical address or contact person addy.
9) What kind of "identifying number" is required for U.S. citizens? Non-U.S. persons? ID # for US person is TIN. For non-US person number from #ID or govt-issued doc evidencing nationality or residence. Procedures are in place for opening accounts without TINs while TINsare applied for but policies may be in place for closing the account after a period of time.
10) Do banks have to actually put their CIP procedures in writing? A bank's CIP procedures must be in writing. There are documentary and non-documentary verification methods. Credit card companies may use 3rd party sources to verify information.
