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#1121962 - 02/03/09 07:06 PM when is a customer not a customer
agent99 Offline
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Joined: Apr 2008
Posts: 240
For CIP purposes, a customer of the bank since 1985, closes his accounts. Six months later, he returns and opens a deposit account. Isn't there some guidance about when a customer ceases to be a customer, thus requiring new CIP if an account is opened? I recall seeing something but can't seem to be able to put my finger on it at the moment.

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#1121981 - 02/03/09 07:24 PM Re: when is a customer not a customer agent99
Skittles Online
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Joined: Sep 2002
Posts: 13,963
TN
Here - unless the individual has a current open account he is new and therefore CIP procedures will be required. Even if he had a CD that he closed out last week we will perform CIP procedures again.
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#1121982 - 02/03/09 07:26 PM Re: when is a customer not a customer agent99
BrendaC Offline
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BrendaC
Joined: Sep 2001
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Sweet Home AL
Is this what you are looking for?

From FinCEN Q&A.
2. Does the exclusion from the definition of “customer” in 31 C.F.R. § 103.121(a)(3)(ii)(C) for a person with an existing account extend to a person who has had an account with the bank in the last twelve months but who no longer has an account?

No, this provision only excludes from the definition of “customer” a person that at the time a new account is opened currently “has an existing account with the bank,” and only if the bank has a reasonable belief that it knows the true identity of the person. Therefore, for example, when a person has a deposit account and subsequently obtains a loan, the person has an existing account with the bank. Conversely, a person would not be deemed to have an existing account at the bank if the person had a loan, paid it off, and twelve months later obtains a new loan.
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#1122476 - 02/04/09 02:40 PM Re: when is a customer not a customer BrendaC
agent99 Offline
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Joined: Apr 2008
Posts: 240
Ah! Thank you Skittles and Brenda.

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