CIP FAQs - Is a new borrower who is substituted for an existing borrower through an assumption of a loan a "customer" to whom the CIP rule applies?

Compliance > BSA > FinCEN FAQs - CIP
Q:  Is a new borrower who is substituted for an existing borrower through an assumption of a loan a “customer” to whom the CIP rule applies?

A:  Yes, a new borrower who is substituted for an existing borrower through an assumption of a loan is a “customer” because the new borrower is establishing a new account relationship with the bank.  (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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