Overview
Use extreme caution when another associate asks you to conduct a transaction on behalf of a client (for example: initial deposit for a new account, loan deposit, and so on). Remember the following:
- Clients must perform their own transactions
- If the client is not physically present, never conduct any check or cash back
- For all transactions including cash back, the client's signature must be included and you must follow all ID requirements
CIP Policy
For traditional accounts, the Client Identification Program (CIP) requires front-line associates to see new consumer account owners and signers face-to-face to request, record, review, and verify identification necessary to prove the identity of the client. Closely examine primary and secondary documents to determine if they appear genuine, have not expired, have not been altered, and otherwise meet our requirements. In certain circumstances, you may also need to use non-documentary verification.
Best Practice:
In an effort to avoid an IRS TIN mismatch, it is recommended to physically view the client's social security card to ensure the number and name match the CIF record.
Non-U.S. citizens must satisfy the requirements on both the Requirements and the Additional Non-U.S. Citizen Requirements tabs.
U.S. citizens must satisfy the requirements on both the Requirements and the Additional U.S. Citizen Requirements tabs.
Businesses must satisfy the requirements on both the Requirements and the Additional Business Requirements tabs.
The policy exists to determine if the information presenter is the person he/she claims to be and/or if the business is a legal entity operating according to state and government regulations.
Accounts are NOT to be opened for U.S. Persons or non-U.S. persons who are unable to produce the required identification. Exceptions to this requirement must be approved by the BSA officer.
Note: A United States citizen is someone who fulfills one of the following conditions:
- A person born in the United States who is subject to the jurisdiction of the United States
- A person who becomes a naturalized citizen of the United States
Requirements
CIP Requirements
Our Client Identification Program (CIP) requires us to obtain consumer information to verify the identity of all individual owners, joint owners, and any convenience signers prior to opening or revising an account. These owners and signers must meet the age of majority requirements for the state where the account is opened.
Minor Checking/Savings
For Level-Up accounts, verify the identity of the parent or guardian. From the minor, obtain his/her legal name, Social Security Number (SSN), date of birth, and physical address; however CIP verification is not required on the minor.
For UTMA accounts, verify the identity of the parent or guardian opening the account for the minor. From the minor, obtain his/her legal name, SSN, date of birth, and physical address.
IMPORTANT: When a minor reaches the age of majority and requests an update to the signature card or the opening of a new account, CIP requirements will apply.
Note: All valid primary IDs must contain a photograph and expiration date unless the issuing state does not contain an expiration date on their IDs. If the state ID card does not expire, enter No expiration date in the appropriate field in the CIF record.
Note: Do not accept post office boxes and mail drop services as the physical address. These may be used for account mailings if the physical address is recorded in the IRS address in the CIF record.
Accounts are NOT to be opened for U.S. Persons or non-U.S. persons who are unable to produce the required identification. Exceptions to this requirement must be approved by the BSA officer.
Additional U.S. Citizen Requirements
As a minimum standard, collect the following information:
- Legal name
- Physical address and mailing address (if different)
- Date of birth
- Social Security Number (SSN) or Individual Taxpayer ID Number (ITIN)
Additional Non-U.S. Citizen Requirements
For resident aliens (issued SSN or ITIN) and non-resident aliens, collect the following information:
- Legal name
- Physical address and mailing address (if different)
- Date of birth
- Social Security Number (SSN) or Individual Taxpayer ID Number (ITIN) *
- W-8 BEN Certificate of Foreign Status of Beneficial Owner for U.S. Tax Withholding
* Note: If you cannot obtain this information, DO NOT open the account. Exceptions must be approved by the BSA officer.
Identification Requirements - No SSN or TIN
CCB clients, business owners, or signers who do not possess Social Security Numbers (SSNs) or Tax ID Numbers (TINs) must either be existing clients or be approved by the BSA officer. They CANNOT be approved through usual procedures.
In addition, they MUST meet the qualifications listed below:
For snowbirds that are seasonal United States residents, obtain a completed W-9 form.
For snowbirds that are not United States residents, obtain a completed W-8 BEN form.
Note: All foreign ID cards must be unexpired, government-issued, demonstrate nationality or residence, and contain a photograph.
To identify non-resident aliens as owners or signers, obtain the following 2 forms of ID:
- Foreign passport number and country of issuance
- Number and country of issuance of any unexpired government-issued document evidencing nationality or residence and bearing a photograph
All forms of ID must be valid and current (not expired). The information we require falls into one of 4 categories as follows:
| Primary ID | Secondary ID | Other Required Information | Inquiry Identification Code (IIC) |
|---|---|---|---|
|
U.S. Citizens
Non-U.S. Citizens
|
|
|
|
Additional Business Requirements
Do not open any accounts for prohibited entities.
Business, Entity, or D/B/A
Beneficial Owner(s) and Controller
CIP requires us to obtain consumer information to verify the identity of the Beneficial Owner(s) and Controller, whether present or not, during account opening or revision. A CIF record must be created for ALL Beneficial Owners and the Controller, even if they are not signers on the account. A Beneficial Owner or Controller not present will be required to provide a photo copy of a primary and secondary form of identification for viewing (the photo copy is to be destroyed after viewing and is not to be imaged). For acceptable forms of identification, see Client Identification Program (CIP) Requirements.
Officer/Owners/Authorized Signers Present (Non-Beneficial Owner/Controller)
CIP requires us to obtain consumer information to verify the identity of the officers/owners/authorized signers present in the office during account opening or revision. For acceptable forms of identification, see Client Identification Program (CIP) Requirements.
Officer/Owners/Authorized Signer Non Present (Non-Beneficial Owner/Controller)
CIP requires us to obtain at a minimum for an officer, owner, or authorized signer without an existing CIF the following information to build a Non-reporting Individual CIF:
- Name
- Address
- Date of Birth
- Occupation
Note: If you cannot obtain this information, do not open the account. Exceptions must be approved by the BSA officer.
See the Verafin Beneficial Ownership Requirement Chart for additional details.