Member Fee: $165
Non-Member Fee: $265
Speaker: Debbie Crawford, gettechnical, inc.
Originally, you wrote your CIP in 2003. Is it time to change? If you have any of the questions below, we will explore changing your CIP in light of new systems, processes and technology. Your program should shift with the new technologies and identifications in the marketplace. This program will look line-by-line at the regulation and point out avenues of change to explore.
What does it mean to “know” your account holder? When do we have to ask purpose, source and anticipated volume questions? How can we enforce compliance with our program in our institutions? These questions are hard ones and the pending legislation on CDD doesn’t help. This program will evaluate CDD and EDD regulation, exam guidance and provide thoughts on how to proceed with a program that is sales friendly to the account holder. We will look at the regulation line-by-line and will discuss to expect with these changes.
- Line by line look at the regulation on Customer Identification Programs
- What Information that must be obtained before an account is opened
- Required Documentary and non-documentary verification
- Should we add more types of identification? What types are available?
- Do we keep CIP up to date?
- How should we address online banking?
- Is non-documentary verification enough?
- Can we back off from our CIP of 2003 now that we have more systems in place?
- Examination expectations on Customer Due Diligence
- Keeping customer records up to date
- Anticipating transactions and activities
- Enhanced due diligence on high risk customers
- Developing the questionnaire
- On-going during the relationship
- When should we close a relationship? And how do we close?
- What regulatory concerns do we have?
- Working with sales and not against them
- A look at CDD rules—beneficial owners, controlling person and the form
- Renewals, IOLTAs, Trusts and Multi-tiered business ownership