Do you interpret the recordkeeping requirements of CIP to literally mean that all of the CIP information (name/address/SSN/DOB, methods of verification (documentary and/or non-documentary), resolution of discrepancy information is to be maintained on 1 “record” for that customer?

Thanks!

No. BSA does not tell you how to keep records, it tells you what records to keep. In general, you must only be able to produce required records within a reasonable period of time.

In addition, the records you mention have different record retention periods. The name, DOB, address & identifying number must be kept for 5 years after the account is closed. The records regarding your verification processes must be kept for 5 years after the information is obtained. Any suggestion or requirement that everything be kept on a single "record" would in effect apply the longer of the two record retention periods to everything.

The identification information (name, address, identifying number, date of birth for individuals) gathered at the time of account opening is to be retained until 5 years after the account in question is closed.

The information about the identification documents and other methods used to verify the identification of the customer (or others controlling the customer's account, including resolving any discrepancies, is to be retained until five years after the record is made.

There is nothing in the regulation that specifically requires that one record must be used, or the format of the record. It is clear that the information to be retained for the life of the account plus five years needs to be separate (or in addition to) from the information about the methods used for verification, unless the bank will retain all of the information for the longer period.