#317119 - 02/15/0511:09 PMCIP Exemptions for Elderly and Disabled Persons
Anonymous
Unregistered
Can someone tell me where in the regulation it states that the above referrenced persons do not have to provide a photo ID for CIP purposes since they most likely will not have one.
Quote: Can someone tell me where in the regulation it states that the above referrenced persons do not have to provide a photo ID for CIP purposes since they most likely will not have one.
The CIP regulation does not mandate that anyone provide a photo ID. The regulation states that a financial institution must obtain certain pieces of information about a customer and must then verify that information through either documentatary or non-documentary verification methods or a combination of both.
The FDIC has a handy "Guidance on Customer Identification Programs" that they issued July 2004:
This guide outlines the elements that must be present in your CIP program. You can have a program that uses other methods to identify the customer, but your CIP must contain risk-based procedures for verifying the identity of the customer.
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CRCM,CAMS Regulations are a poor substitute for ethics. Just sayin'