Managing Compliance With Your Customer Identification ... - IIR

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Recent Guidance Agent Lending – April 26, 2006 (1) the agent lender’s customer does not initiate the transaction, (2) the agent lender determines the securities that will be used to fulfill the broker-dealer borrower’s request, (3) the broker-dealer borrower records the loan transaction into an account in the name of the agent lender, and (4) the information about the agent lender’s customer is generally provided to the broker-dealer borrower after the fact and principally for the purposes of determining credit risk and reporting regulatory capital.
Section 326 – <strong>Customer</strong> <strong>Identification</strong> Program Basic Requirements Definition of Account - A formal or contractual relationship with a financial institution to provide financial products and services *Exceptions include: ERISA Accounts Transfer exception - Accounts acquired through acquisition, merger, etc.
Page 1 and 2: Managing Compliance With Your Custo
Page 4 and 5: Customer Identification Program is
Page 6 and 7: When are CIP and KYC complete? a) O
Page 8 and 9: When are CIP and KYC complete? a) O
Page 10 and 11: At Account Opening: ‣Determine ap
Page 12 and 13: Screening Capabilities: Enable effi
Page 14 and 15: External Information Sources •Com
Page 16 and 17: Internal Information Sources - The
Page 18 and 19: Summary CIP and KYC is an ongoing e
Page 20 and 21: Definition of Customer includes: De
Page 24 and 25: Core Four Identification Informatio
Page 26 and 27: CIP vs. KYC/Due Diligence • CIP i

Managing Compliance With Your Customer Identification ... - IIR

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