Customer Identification Program (CIP) requirements and non-U.S. persons

Happy early Thanksgiving! Amongst many other things, I am thankful that social media filters work on my cat, Quincy, so I can take fun holiday photos of him to share.

This week, my blog is going to focus on Customer Identification Program (CIP) requirements and non-U.S. persons. I have been getting quite a few questions on this lately, so I thought a blog refresher may help.

The PATRIOT Act and federal regulations require each credit union to implement a written Customer Identification Program (CIP) that includes certain minimum requirements, such as the collection of identifying information at account opening and risk-based identity verification procedures. The purpose of the CIP is to allow the credit union to form a reasonable belief that it knows the true identity of each customer.

The CIP rules are found in section 748.2(b)(2) of the NCUA regulations and section 1020.220  of the FinCEN regulations.


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