The borrower identity-verification checklist runs the framework against the Customer Identification Program framework, the FinCEN Beneficial Ownership framework, the OFAC sanctions-screening framework, the taxpayer-identification-number framework, and the entity-authority-documentation framework on the loan-boarding cycle. This article walks the five-step framework against the checklist build on the lender’s platform.

Step 1: Map the CIP data elements

The Customer Identification Program framework runs four data elements against each natural-person borrower — the full legal name, the residential address, the date of birth, and the taxpayer-identification-number framework. The lender runs the verification framework against a government-issued photo-identification document framework — state-issued drivers license, state-issued identification card, United States passport, or foreign passport with the I-94 framework — against the four data elements on the boarding cycle.

Step 2: Build the entity-borrower framework

The entity-borrower framework runs the FinCEN Beneficial Ownership Information framework against the entity formation cycle. The lender runs the verification framework against each natural-person beneficial owner on the substantial-control framework or the ownership-interest framework above the FinCEN-defined ownership threshold. The framework runs the four CIP data elements against each beneficial owner on the framework.

Step 3: Build the entity-authority framework

The entity-authority framework runs the signer-authority documentation framework against the entity borrower. The limited liability company framework runs the articles of organization, the operating agreement, the certificate of good standing, and the manager-or-member-resolution framework against the signer-authority cycle. The corporation framework runs the articles of incorporation, the bylaws, the corporate resolution, and the incumbency-certificate framework against the signer-authority cycle. The limited partnership framework runs the certificate of limited partnership, the limited-partnership-agreement framework, and the general-partner-authority framework against the signer-authority cycle. The trust framework runs the certification of trust, the trust-agreement framework, and the trustee-authority framework against the signer-authority cycle.

Step 4: Build the OFAC and TIN framework

The OFAC sanctions-screening framework runs the Specially Designated Nationals and Blocked Persons List framework against each natural person and each entity on the boarding cycle. The framework runs the screening framework against the consolidated-sanctions-list framework on the OFAC framework. The taxpayer-identification-number framework runs the Form W-9 framework against the United States borrower and runs the Form W-8BEN framework against the foreign borrower. The framework runs the IRS TIN-matching framework against the borrower’s name and taxpayer-identification number on the IRS framework.

Step 5: Build the audit-trail framework

The audit-trail framework runs the verification-recordkeeping framework against the loan-boarding cycle on the lender’s servicing platform. The framework runs the verification-document framework, the verification-method framework, the verification-date framework, the verification-officer framework, and the exception-and-escalation framework against the loan file. The framework runs the recordkeeping framework against the regulatory-retention cycle on the Bank Secrecy Act framework. The framework runs the beneficial-ownership recordkeeping cycle on the Corporate Transparency Act framework. The framework runs the taxpayer-identification recordkeeping cycle on the IRS framework.

Related Topics

This article is educational and does not constitute legal, regulatory, or tax advice. The identity-verification framework runs against the Bank Secrecy Act framework. The framework runs against the USA PATRIOT Act §326 Customer Identification Program framework. The framework runs against the Corporate Transparency Act beneficial-ownership framework. The framework runs against the OFAC sanctions-screening framework and the IRS framework on the lender’s recurring compliance cycle. Consult qualified legal counsel and a tax adviser on the specific identity-verification framework against any private-lending operation.

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