Changing the CIP Program to Reflect Address Verification
Answered by BOL Gurus Mary Beth Guard and Jack Holzknecht Bios
Question: If our CIP program allows for address verification to be performed after account opening are you saying we need to change our CIP Program to reflect the address verification must be performed before account opening.
Answer: You need to make some change. You may adjust your CIP program or you may use information other than CIP information to form a reasonable belief that the consumer report relates to the consumer about whom you requested the report
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