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#316334 - 02/15/05 04:48 AM CIP
Anonymous
Unregistered

We obtain the 4 required items in CIP. Our policy states that we may use nondocumentary or other documentary methods as deemed necessary (i.e., letters, call backs, etc obtain other ID). We OFAC all new customers with no existing relationship, and run ChexSystems. We basically leave it up to the discretion of our customer service associates to determine if they will get additional information. Our policy also has a risk rating system of the different levels of risks for the various products and required elements. Does anyone think that this is not adequate as far as what regulation requires ?

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#316335 - 02/15/05 05:18 AM Re: CIP
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Do the customer service folks opening new accounts have guidance for their decision making re documentary vs non-documentary? Also, is their a record made of what they did and why? Can it be tested and how are the results? If yes and the results are good,then I think you are okay.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
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#316336 - 02/15/05 03:01 PM Re: CIP
Anonymous
Unregistered

Our policy states situations where non-documentary methods my be used, i.e., bank not familiar with identification presented, individual unable to present other identification with a photograph. We may send a thank-you card, contact them by telephone. I don't think we have it in writing as to what they used in each case.

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