Account Opening Authority and Documentation
Chapters in this video
What this video covers
- The four items that must be collected strictly before account opening: name, address, date of birth for an individual, and identification number, plus the limited exception when a taxpayer identification number is pending application
- Why collection and verification of identity have totally different timing rules, with verification permitted a reasonable time before or after opening
- How documentary methods (government-issued photo identification, formation documents) differ from non-documentary methods (credit checks, financial statements, contact with customer) and when additional due diligence on controlling persons is required
- The mandatory federal watch list check against known or suspected terrorists and terrorist organizations designated by Treasury
- Why account acceptance by a partner, officer, or manager is a separate requirement from a legal entity's authority to transact, and whose signature the exam expects for each
- What the required account record must show: customer identity, responsible associated persons and their scope, the account acceptance signature, and each authorized person for a legal entity
- Why completing identity verification does not fulfill know your customer (KYC) obligations, and what essential facts KYC requires beyond simply proving identity
- What standing settlement instructions (SSI) are and the three things they cannot replace: identity verification, transaction authority, or account acceptance
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