Did you change your CIP program for your ITPP to cover the opening of a new covered account by an existing customer?

We did not. But we have increased from just Chex Systems to a product that will check customer info through a variety of databases for ID Theft purposes. Each new account (not just new customers) will be run through this system.

Rizzo - how much is that going to cost per customer and how long is it going to take? Are you doing the verification while the customer is at the desk or after they leave?

HMS, I believe the cost will be about $3 per inquiry. The inquiry will be done at account opening. If they don't "pass" then we won't open the account.

And PS...I love your sig line!

I don't think I'll sell the bank on $3 OR on doing it at account opening, but I'll see how it goes - I may PM you for more info on vendors if that's OK.

Feel free!

I'm getting in to this a little late in the game because of some staffing changes, so please forgive my ignorance as I try to catch up.

We just upgraded to "chex-systems on steroids" at our bank, too. Before Red Flags, we just checked ChexSystems on new accounts for new customers. If an existing customer opened a new account, we just went ahead and did it.

Are we now required to check for the existence of Red Flags (via Chex Systems, in our case) for even existing customers? Or, since the regulation is geared towards a risk-based approach, can we just keep doing what we have been doing and not checking Chex-Systems when an existing customer comes in to renew a COD or to open a new account?

Where can I find this in the Reg?

I basically have the same question. I developed a checklist for ID Theft Red Flag Guidelines for new accounts but we're having trouble using it if the new CD (for example) is for an existing customer. We haven't been getting their ID again since we already know them, therefore several of the questions on my checklist don't really apply. Do most bankers get ID for existing customers? Do you run Chex Systems on existing customers if they open a new checking account?

Prior to "Red Flags", we did not. We had already established the customer relationship and verified their identity...why incur additional cost to get information we already got once, right? But we are doing so now. Each inquiry is costing just over $5 and our expenses are skyrocketing.

We don't run Chexsystems unless we can't verify their identity through our internal information. You should already have information that you can use to verify their identity. Our checklist has a section for existing customers that starts off with the question "Do you know this customer personally?" If the answer is yes - the checklist is complete and the additional account is opened. If the answer is no - the next questions directs the employee to verify their identity through ID and internal information we obtained in the CIP process.