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#110933 - 08/29/03 03:26 PM CIP - banks we acquire
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If we acquire a bank in January 2004, for example, are we required to maintain the CIP records they created on their customers from October 1 to the time of the acquisition? I know that accounts obtained through an acquisition are exempt, but I am not sure what the requirements are regarding the CIP records of a bank we may acquire.

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#110934 - 08/29/03 11:37 PM Re: CIP - banks we acquire
Kathleen O. Blanchard Offline

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If you are acquiring the bank, and those customers are going to be your customers, why would those records not just come along with all of the other customer records? Whether the bank remains an separate entity or is merged into your bank, those are customer records and must be retained, just as you would retain all of their old transactional records. Otherwise, you would have to "re-id" the customers.
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#110935 - 09/02/03 10:46 AM Re: CIP - banks we acquire
Elwood P. Dowd Offline
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Your responsibility to retain the records would be the same as the bank you acquired. The transfer exception means that you are not required to do CIP on accounts purchased or assumed; it does not diminish any requirement to keep records of the fact that CIP was performed by your predecessor.
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#110936 - 09/02/03 02:34 PM Re: CIP - banks we acquire
Lestie G Offline

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What if the acquired bank has inadequate CIP procedures and records? What's the liability to the acquiring bank?
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#1316896 - 01/04/10 05:18 PM Re: CIP - banks we acquire Lestie G
AnnRoy Offline
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AnnRoy
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Need guidance on this since we are approaching the core platform conversion of a bank we acquired - the acquired bank images their CIP worksheets which will not be converted to the designated fields on our core because of the imaged format.

Q: Are we required to enter their CIP information on our core which will be labor intensive project? Since we have to maintain the CIP records, my immediate reaction is to have their acquired bank print a copy of all of their imaged CIP worksheets.
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#1316907 - 01/04/10 05:23 PM Re: CIP - banks we acquire AnnRoy
John Burnett Offline
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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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#1316911 - 01/04/10 05:25 PM Re: CIP - banks we acquire AnnRoy
Kelsey D Offline
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Ohio
Originally Posted By: AnnRoy
Q: Are we required to enter their CIP information on our core which will be labor intensive project? Since we have to maintain the CIP records, my immediate reaction is to have their acquired bank print a copy of all of their imaged CIP worksheets.


I'd keep a copy of their imaged CIP information, whether it's a hard copy or electronic one, put it into retention, and hope that you never have to retrieve something from paper copies.
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#1316912 - 01/04/10 05:26 PM Re: CIP - banks we acquire AnnRoy
Kathleen O. Blanchard Offline

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Can you save the images electronically so that they can be accessed in the event any of those records are ever requested? If you could have some flag or other method so that you knew x customer came from that bank, you would then know where to obtain the related CIP data.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1317352 - 01/04/10 10:12 PM Re: CIP - banks we acquire Kathleen O. Blanchard
AnnRoy Offline
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AnnRoy
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South
Thanks all for the responses! I'm working with the acquired bank to see if the CIP worksheets can be retained in an electronic format instead of printing the copies.

Kaybee, I like your suggestion about creating a flag on our core to identify those customers where the CIP info can be retrieved.
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