CFTC, FinCEN and Treasury have provided guidance in a Q&A format regarding certain unique circumstances relating to IBs and the Customer Identification Program (CIP). These include: New Co-Owner of Account: If a person becomes a co-owner of an existing account, then the new co-owner is a customer to which the IB must perform the CIP. Rural Customer Without Address: If a customer lives in a rural area and does not have a residential or business address, then the IB may get the number on a roadside mailbox on a route route. A route route is a description of the approximate…