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#349022 - 04/20/05 03:22 PM CIP-existing customer
Lesley Offline
New Poster
Joined: Mar 2005
Posts: 3
We have a customer who closed their loan in March and they are now getting another loan. Do we need to do CIP again because they do not have an account currently? Our policy does not address this issue, so I am assuming we will have to do it again.

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BSA/AML/CIP/OFAC Forum
#349023 - 04/20/05 03:31 PM Re: CIP-existing customer
GreatBlue Offline
Diamond Poster
GreatBlue
Joined: Feb 2003
Posts: 2,362
Colorado
The existing customer exception to CIP only applies if they currently have a relationship with your bank. This customer would be subject to CIP.
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#349024 - 04/21/05 07:31 PM Re: CIP-existing customer
yorockie Offline
Member
Joined: Jun 2004
Posts: 77
My own private island
This is referenced in the guidance published by FinCEN. It is a FAQ document that addresses common CIP questions. http://www.fincen.gov

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