BSA/AML, CIP: Patriot Act & Unincorporated Associations
Printer-friendly VersionQuestion:
Are the individual signers on the signature card of an unincorporated association RE: to the mandates of the Patriot Act?
Answer:
No. See the definition of "customer" in the CIP rules. It means "An individual who opens a new account for: ... (2) An entity that is not a legal person, such as a civic club." See 31 CFR 103.121. The first draft of the rule would have included all signatories. That provision was hotly opposed by the banking industry successfully!