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For a mortgage loan, do we need to have CIP information & a tax ID number for an insurance company before we pay the company from an escrow account? – IBA Compliance Connection

IBA Compliance Connection

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For a mortgage loan, do we need to have CIP information & a tax ID number for an insurance company before we pay the company from an escrow account?

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We do not believe that your CIP would apply to an insurance company that simply receives checks from the bank. The CIP rules apply only to “customers,” defined as an individual or person that “opens a new account.” 31 CFR 1020.100(c)(1)(i).

However, you may be required to obtain a tax identification number for purposes of making payments to the insurance company, for example if the bank will be issuing a 1099-MISC form for the payments. (See the IRS instructions for the 1099-MISC form.)