Using Your Old KYC Policy To Create Your New CIP

Question: I know that under the terms of the USA PATRIOT Act we're supposed to have a CIP - a Customer Identification Policy. I spent a lot of hours writing a Know Your Customer policy a while ago. Can I just rename it and use that?

Answer: Not quite, but you can use a lot of it. There are special requirements under the USA PATRIOT Act that weren't in KYC, and some things you "suggested" they do in KYC are now mandated - there is no choice about whether to do them or not. A revision, rather than a rewrite, is certainly a possibility. Just remember that what you have in the policy must be what you are actually doing. It just isn't good enough to write it right and then do it wrong. If you want to start over, check out the CIPs on the BankersOnline web page. There are a couple of samples there in Bankers Tools that you may find very useful.

Copyright © 2002 Bankers' Hotline. Originally appeared in Bankers' Hotline, Vol. 12, No. 8, 10/02