Where a bank is entitled to rely on another financial institution to perform its CIP, whose CIP must the relied-upon financial institution implement?
The reliance provision does not impose on the other financial institution the obligation to duplicate the procedures in the banks CIP. The reliance provision permits a bank to rely on another financial institution to perform any of the procedures of the banks CIP, meaning, any of the elements that the CIP rule requires to be in a banks CIP: (1) identity verification procedures, which include collecting the required information from customers and using some or all of that information to verify the customers identities; (2) keeping records related to the CIP; (3) determining whether a customer appears on a designated list of known or suspected terrorists or terrorist organizations; and (4) providing customers with adequate notice that information is being requested to verify their identities. Note that a bank can only use the reliance provision when the other financial institution is regulated by a Federal functional regulator and is subject to a general BSA compliance program rule, they
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