CIP ID Guidelines
Question: For our customer identification program, I cannot find where it says we must have two forms of ID. Can you direct me to the correct place?
Answer: The proposed CIP rules would have required two forms of picture ID. The final rule relaxed this requirement and only directly requires one form of picture identification from the customer. However, the rule sets the minimum requirement. Your policies and procedures must be based on a risk analysis of your market. You may conclude that one valid government-issued identification is enough to establish identity in your market. Or you may conclude that your market is high risk and that more than one form of identification should be obtained from each customer.
In addition to the standard identification procedures for customers, you should also have guidance on how to proceed when, for whatever reason, the identification document offered by the customer does not seem to be sufficient. This may be because the customer and the identification document don't quite make sense. For example, a customer with an address in your market produces a drivers license issued by another state. Or it may be because the document is not convincing - there is a possible flaw or indication of tampering. Your procedures should specify what staff should do next to establish the customers identity and bona fides.
In addition, your staff should have guidance on what information to request to support the documentation given or the concerns raised. Documents such as utility bills indicating a current status, a lease or even an employment contract can all be used to explain a new and legitimate presence in the market.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 4, 5/04>/span>
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