Has anyone seen any authoritative guidance giving a definition or examples of "substantive discrepancy" for CIP? I just want to see if it is anywhere in writing that I can refer to, instead of relying on different interpretations. I have searched and found nothing. I was hoping the new BSA examination manual would have addressed this but it did not.

Thanks.

anyone?

I believe an example would be that information provided by the customer does not match the government issued identification. For example, the name doesn't match or the address. Could be the customer just got married or they moved.

In above example, what is acceptable resolution? For example, "just moved"...is it enough to document that the customer states they just moved or do we need proof? If "proof", what?

I would like to know how banks resolve the driver's license address matter?

I go to a bank near my new residence to open an account. I've just moved to the Carolinas from Massachusetts and I don't yet have a new license. So there will be a substantive discrepancy between information on my license and the information I provide to open the account -- my two addresses.

I could supply a copy of the lease for my new rented apartment, or the settlement statement for the financing of my new residence. Or I could have waited until after I got my new license.

Thanks from the original anon!