I know most CIP policies require two types of I.D., one primary(photo I.D.) and one secondary. Does BSA reg. require two types of I.D.?

The USA Patriot Act requires your bank to create a policy for CIP. This may include different identifications for different kinds of accounts and account openers. Whatever your bank decides it should do so from a risk-based prospective and verify the identity of the customer.

I would disagree that "most CIP policies require two types of I.D.". Most that I review require only 1. As Shemp pointed out, CIP requires you to create a policy that is risk-based. CIP requires you to verify enough info so that you are reasonably satisfied they are who they say they are."

You might want to review Q&A's 1-4 of the "31 C.F.R. § 103.121(b)(2)(ii) -- Customer verification" section of the new/revised CIP Q&A's. Also, review Q&A #2 of the section entitled "31 C.F.R. § 103.121(b)(3)(ii) – Retention of records".