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Updated 12-27-22. Signing Agents must deal with a wide variety of different documents during a loan signing, and many of them come with particular or unusual instructions. In this article, we answer frequently asked questions about the USA PATRIOT Act Customer Identification Program Form.
What is the purpose of the USA PATRIOT Act CIP Form?
Signed into law in 2001 in the wake of the 9/11 terror attacks, the U.S. PATRIOT (Providing Appropriate Tools Required to Intercept and Obstruct Terrorism) Act established measures to prevent, detect and prosecute persons engaging in money laundering and terrorism. In 2003, regulations to implement Section 326 of the Act required all financial institutions to establish a Customer Identification Program (CIP) for identifying all new account holders. This requires banks and other lending institutions to have a written procedure in place to establish the identity of customers, including home loan borrowers.
Because Notary Signing Agents must already positively identify borrowers during a loan document signing to execute acknowledgments on a mortgage or deed of trust, Signing Agents are often asked to complete a USA PATRIOT Act CIP form to certify the NSA properly identified the borrower at the signing appointment. Completing this form helps financial institutions, including the nation’s mortgage lenders, to fulfill their PATRIOT ACT regulatory obligations.
Are there other terms for a USA PATRIOT Act CIP Form?
Yes. It may be included in a loan package under other names, such as “Verification of Customer Identity,” “PATRIOT Act Information Form,” or “PATRIOT Act Disclosure — Borrower Identification,” among others.
What types of loan document packages include a USA PATRIOT Act CIP Form?
These forms have been regularly included in various types of loan packages since 2003.
Does a USA PATRIOT Act CIP form require notarization?
No, it does not. But because a Notary Signing Agent is present at the loan signing involving a lender’s loan, the NSA represents the lender in obtaining the information required in the form.
What information is required to complete a typical PATRIOT Act form?
Typically the Signing Agent will be asked to complete the following information on the form:
- The name of the borrower(s), along with other information such as the borrower’s date of birth, Social Security number or tax ID number.
- Information about any identification documents used to verify the borrower’s identity, such as the type of ID, the ID identification number, and the date of issuance and expiration for the ID. Some forms may also ask the NSA to include the state or organization that issued the ID.
David Thun is the Assistant Managing Editor at the National Notary Association.