An account can be maintained in compliance with CIP as long as the required records are obtained and recorded.

• True
• False

Cash transactions must be aggregated for CTR reporting purposes when closely owned but separately incorporated business accounts comingle funds to the extent they have lost their separateness.

• True
• False

The Bank must file a CMIR on behalf of a customer who wishes to deposit over $10,000 in currency that she received from outside the United States.

• True
• False

If the information required for a CTR is not available, the institution should either not conduct the transaction, or should offer to revise the transaction so that the threshold is not met and a CTR would not be required.

• True
• False

Monetary instrument sales records should be periodically tested to verify that large cash purchasers and identified remitters have required ID on file (i.e., either as a deposit accountholder or in other log/records).

• True
• False

A bank must be sure to obtain and maintain updated and unexpired ID information under the CIP regulations and retain those for the required retention period.

• True
• False

The following are true regarding a Bank's Customer Identification Program, EXCEPT:

• More than one of the below are untrue.
• CIP requirements can be waived upon approval of a senior bank official.
• An account can be opened with an "applied for" taxpayer ID number so long as it is obtained within a reasonable time after opening.
• Existing customers are not subject to CIP requirements.
• CIP related records must be retained for 5 years from account opening.

On Tuesday at noon, Ann deposits $6,000 at Bank A into her joint account with her husband. At 5pm that day, she deposits $8,000 to her business account at Bank A.

• The institution must file a CTR for $14,000 deposited by Ann.
• No CTR is required because the beneficiaries don't match.
• The institution must file a CTR for $14,000 deposited by, and for the benefit of, Ann and reports her husband as an additional beneficiary.
• The institution must file a CTR for $14,000 deposited by, and for the benefit of, Ann and reports her husband and her business account as additional beneficiaries.
• Whether a CTR is required or not depends on the institution's cutoff time for posting deposits. It is possible the 5:00 pm deposit would post on the next "business day" and would not be aggregated for CTR purposes

Regarding CTR exemptions:

• A Congress mandated a simpler process to encourage more exemptions.
• B Nothing is required to exempt a domestic bank from which the institution receives currency.
• C Once a customer is exempted, none of their cash transactions require reporting.
• A and B are true
• A, B and C are true

The following are non-documentary ways to verify Identification under the CIP EXCEPT:

• Send a thank you letter to the customer's address.
• Copy the customer's driver's license.
• Obtain a digital certificate.
• Obtain financial statements or tax returns.
• Pull the customer's credit report.