Questions and Answers
Are we required to apply our customer identification program to entities which are publicly traded or to wholly owned subsidiaries of a U.S. publicly traded company? If so, would documentary evidence such as a corporate resolution suffice for verification purposes?
The customer identification program regulation does apply to business accounts and does not contain any exceptions with respect to the type of entity involved. Your CIP should specifically address how you will approach publicly traded entities. That being said, you will need to collect the basic pieces of information from the entity opening the account—business name, address (which may be a principal place of business, a local office or other physical location) and an employer identification number. Presumably there is less risk in knowing the true identity of a publicly traded company so the collection of documentary evidence, such as a corporate resolution, should be sufficient.
(Posted: 05/15/2008)
