Let me see if I have this correct...If an existing customer opens a new account with us, we have to perform CIP? Where does it say this in the act?

Let me clarify my question above...I have been discussing this with my team....if an existing customer (who has a DDA account, and has since prior to 10/01/2003), opens a new account, do we still need to perform CIP?

I was under the impression that due to the definition of "customer" under the act, that we would not be required to do this. I thought that the standard was "if the bank has a reasonable belief that it knows the true identity of the customer," then they do not need to be run through CIP. On the same note, I do think it would be a best practice to gather any missing info, but that would be a procedural enhancement, not a regulatory requirement.

Thanks for your help.

Your requirements need to be spelled out in your policy. Your examination will be based on the adherence to your banks policy - as long as it meets the minimum requirements. Here, we do not identify current customers, but will identify someone if they previously had an account and it had been closed.

You are right that the standard for exempting existing customers is if the bank has a reasonable belief that it knows the true identity of the customer. Be aware though, that under the CIP exam procedures regulators may require you to submit a written description of your institution's rationale for exempting existing customers to see whether your policy is reasonable.