Same here Kay. We just went through FCIC Compliance, Safety and Soundness, and the State Exam (all at the same time and nobody wonders why I have white hair and drink, just kidding about the white hair) I can e-mail you my form if you want- we interpreted CIP's definition of a new customer for our loan department as when we close a loan and dispurse funds they become a new customer therefore we gather ID info at closing through the attorneys. The key here is auditing the attorneys for compliance with our procedures, and we do on every file closed. We also have an existing customer exemption on the form. Let me know if you would like to see if my form will suit your needs.
_________________________
Humility about how little I know has encouraged me to listen more carefully and more wisely.
John Templeton