Question: I require some clarification on the record retention for CIP. Are the record retention requirements
different for the deposits side and loans side? Is there a record retention chart that would be helpful?
Answer: There are only two types of record requirements for CIP purposes, so it’s simple enough you
don’t really need a chart. You must retain the customer’s name, address, identifying number (and date of birth, if the customer is an individual) until five years after the account is closed. The second type of record retention relates to your documentation of the methods you used to verify identity. The record of the method(s) you used to verify each customer’s identity must be kept for a period
of five years from the date the record is made. As for differences in the CIP record retention requirement for deposits versus loans, there are no differences.
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