AnnRoy --
You are required to keep the records. Treasury rules don't make any allowance for banks that are inconvenienced by the vicissitudes of mergers and acquisitions. If you are asked by an examiner for a CIP-related record that you should have, the examiner may be sympathetic to your plight as an individual, but your exam report will reflect a violation if you can't produce the record.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8