We are starting to image everything and have come up with some glitches (we think). I need some input
3/2002 open deposit acct; CIP info on application
6/2002 open loan w/ "existing customer" for CIP
10/2003 close deposit acct
10/2008 delete deposit acct and all info (including CIP)
12/2008 open new loan w/ "existing customer"PROBLEM cuz all CIP info from original deposit acct is gone
?????? Could we keep the CIP info in a general CIF file for the customer and base subsequent accts off of it????? Even if the documents are expired?????? I would appreciate some thoughts on this. How are other people doing it?

First, if the customer has no open accounts, he is not a customer for CIP purposes even if the last account closed two days ago. You may use some of the same information you used last time, but you cannot use "current customer" to bypass ID verification altogether.

Second, the CIP information that you obtained (the four elements of ID) has to be retained for five years following the close of the account(s). The description of any document (like a license) relied on, or other methods used to verify the ID, and any resolution of a discrepancy, must be retained for five years from the creation of the record. (see 31 CFR 103, § 103.121(b)(3)(ii))

So you have two problems with deleting the CIP information. Note also that in 12/2008 opening the account with "existing customer" would be a violation even if you still had the information in file (because it isn't an existing customer!)

I think what I am reading is ... you still have the Loan for this customer from 06/2002. But you no longer have any information since all you have are the words "existing customer".

Yes you could "keep the CIP info in a general CIF file for the customer and base subsequent accts off of it. Even if the documents are expired" (CIP is based on what you initially verified) ... however I would focus more on training your staff to always gather CIP info (or always carry it over) - so you don't run into this again.

In this case I believe you are "SOL" & need to gather the information & be prepared for this situation to come up again in the future.

I keep our CIP information on our CIF files also. We do not have the flexablity to say when our files are scrubbed and the info deleted. I depend on my maintenance reports that shows the infomation being input at the time that the account was opened.