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.

 

continue reading »