Questions and Answers
If a check payable to a third party is endorsed over to our customer, and our customer deposits it, does CIP require us to record and verify identity information regarding the third party payee?
The customer identification program (CIP) regulations indicate that you are required to record and verify identity information only with respect to a “person that opens a new account”. There does not appear to be any way that your customer’s deposit of a check payable to a third party and endorsed over to your customer can be deemed to be the opening of a new account by the third party payee. Thus, it appears that the CIP regs do not require you to record and verify identity information regarding the third party payee.
(Posted: 04/24/2008)
