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ID and Re-ID for CIP?
Answer by David Dickinson, BOL Guru
Guru Bios
Question:
Do you have to keep identifying your customers over and over again after you have positively identified them per the Customer Identification Program Section 326 of the USA Patriot Act? Furthermore, is it required to even ID existing customers as they continue to do business?
Answer:
You need only identify and verify your customers (per CIP) once. Existing customers are exempt from the CIP requirements provided the financial institution has a reasonable belief they know the true identity of the customer.
First published on BankersOnline.com 2/12/07
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