CIP FAQs - The CIP rule applies to a "customer." At what point does the CIP rule apply when the account is a loan? When is the account opened?

Compliance > BSA > FinCEN FAQs - CIP
Q:  The CIP rule applies to a “customer,” which is generally “a person that opens a new account.” (Emphasis added.) At what point does the CIP rule apply when the account is a loan? When is the account opened?
 
A: “Customer” does not include a person who does not receive banking services, such as a person whose loan application is denied.  See 68 FR 25090, 25093 (May 9, 2003).  Therefore, when the account is a loan, the account is opened when the bank enters into an enforceable agreement to provide a loan to the customer.  (January 2004)
 
 
ADDITIONAL INFORMATION
This FAQ was excerpted from the Interagency Interpretive Guidance on CIP Requirements that can be found at the following link:  https://www.fincen.gov/sites/default/files/guidance/faqsfinalciprule.pdf
 
 

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