New Business Accounts: The Interview, CIP, New CDD Rules and Authority

It’s a big job to "know your customer" from identification, documents, questions, risk and to script this process into a fluid on-boarding process. This program will focus on building the process from different types of entities to different types of risk.

There are many types of business accounts with many ways to do business at banking today. It can be challenging to determine who is authorized to open, close and transact business when dealing with so many business entities. In addition to opening accounts in person for businesses, we now bank businesses online, with debit cards and through remote deposit. Because of these multiple entities and various approaches to opening accounts numerous questions arise. How do we set up these accounts and then change them as the businesses change? What happens when a partner dies? What happens when the sole proprietor dies? Can you keep the same EIN if a sole proprietorship incorporates? What if the LLC members are other businesses? How do they sign? We will look at tax issues when a business is disregarded and reported in a different tax number. And the list of questions goes on. Understanding designations, rules and authority on all different types of business accounts can assure that you are taking the proper precautions and can assist you in avoiding errors that can be costly to your organization.

New Customer Due Diligence will change how you open and document your legal entity customer. This program will address how to complete beneficial ownership forms, how to script the business account interview to include beneficial ownership, purpose, and nature questions. You will receive a business documentation handout to assist you in creating checklists plus some sample situations which will demonstrate how to run your CIP on the business, signatories and beneficial ownership. The FATCA rule has a component on foreign financial institutions which began on January 1, 2015 for foreign institutions and businesses. We will review new account opening procedures for foreign financial institutions and foreign financial entities and the new W-8BENE.

The regulators are now asking for a new account script. When you receive your request letter items for your compliance examination, will you have a new deposit account script? If not, this is the program for you.

Covered Topics:

  • Sole Proprietorship Accounts
  • Partnership Accounts
  • Corporations
  • Limited Liability Companies (LLC)
  • Nonprofit Organizations
  • Exemptions for CDD
  • Record Retention
  • Transactional questions
  • Assigning Risk
  • Developing a Script

Who Should Attend?

New Accounts, Personal Bankers, Branch Administration, Deposit Operations, CIP Managers, BSA Officers, Training and Business Development Personnel