Welcome to the on-line
March - April 2004 issue of the
Community Bankers' Advisor
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The Advisor is
prepared by attorneys at Olson & Burns, P.C. to provide information
pertaining to legal developments affecting the field of banking.
In order to accomplish this objective, we welcome any comments
our readers have regarding the content and format of this publication.
Please address your comments to:
Community Bankers' Advisor
c/o
Olson & Burns, P.C.
PO Box 1180
Minot, ND 58702-1180
olsonpc@minotlaw.com
Also,
visit our web site at:
www.minotlaw.com
The attorneys
at Olson & Burns represent a wide range of clients in the financial
and commercial areas. Our attorneys represent more than 30 banks
throughout North Dakota. |
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On January 8, 2004, the OCC issued a bulletin announcing
that a "Frequently Asked Questions" publication had been produced
for guidance regarding the Customer Identification Program rule. We
reprinted the first portion of the FAC in the January/February, 2004,
issue. The second portion is reprinted below, and the balance of the
publication will be reprinted in the May/June issue of the Community
Bankers' Advisor.
FREQUENTLY ASKED QUESTIONS:
Final Customer Identification Program Rule
(Reprint of OCC 2004-3 Attachment)
31 C.F.R. ' 103.121(a)(3)(ii)(C) B Person with an existing
account
1. A loan and a time deposit are each an "account"
for purposes of the CIP rule. How do the requirements of the CIP rule
apply to a loan that is renewed, or a certificate of deposit that is
rolled over?
The CIP rule applies to a "customer," generally, "a person
that opens a new account." 31 C.F.R. ' 103.121(a)(3)(i). (Emphasis
added.) "Account" means a formal banking relationship established
to provide or engage in services, dealings, or other financial transactions
including a deposit account, a transaction or asset account, a credit
account, or other extension of credit. 31 C.F.R. ' 103.121(a)(1)(i).
For purposes of the CIP rule, each time a loan is renewed or a certificate
of deposit is rolled over, the bank establishes
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