Are Former Customers Considered "New" Customers? - Ken Golliher

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Are Former Customers Considered "New" Customers?
Answer by Ken Golliher, BOL Guru
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Question: How does the new Patriot Act regarding CIP address closed accounts? What I mean is if a customer has closed an account but still is on our operating system with all information, are they considered a new customer if they come in to open a new account?

Answer: The regulation creates a possible distinction for customers with "existing" accounts. It's pretty objective, they either have a formal banking relationship with you at the time the new account is opened or they do not.

First published on BankersOnline.com 8/25/03

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