CARH’S BROADCAST E-MAIL – Regulatory Update
Rural Development (RD), recently published a May 12, 2021, Unnumbered Letter (UL) entitled, “Supervised Bank Accounts.” The UL replaces any previous ULs on this subject.
According to RD, the UL was reissued in response to questions on Supervised Bank Accounts and the need for RD employees to provide identification. However, because federal agencies are not considered “customers” for the purpose of Customer Identification Program regulations, financial institutions are not required to obtain CIP information from federal agencies opening an account. Government officials, with signature authority and acting the course and scope of their official duties, fall under this exemption. A copy of the UL can be provided to bank compliance officers to document the exemption.
This UL is only applicable to Single Family and Multifamily programs with Supervised Bank Accounts. Multifamily property owners no longer using Form RD-402-1 “Deposit Agreement” do not require countersignature. Therefore, there are no additional identification requirements.
If you have any questions or comments on these UL’s, please contact the CARH national office at firstname.lastname@example.org or 703-837-9001.