Suppose a minor opens a savings account and the bank collects and verifies the information of the minor's parent. When the minor becomes an adult and opens a checking account, does the bank have to verify the minor's identity or can it exempt the minor as an existing customer? I think the bank should verify the minor's identity, but I do not see anything in the reg that specifically addresses this issue.

The Reg is only triggered by a new account or service. Finally being old enough to vote (and buy beer in some states) doesn't trigger the Reg at all.

It's still a good practice to get a "legal" signature from the now-adult on any account agreements, but CIP doesn't require it.

When the minor turns 18, we require him or the adult on the account to close the account & open a new account. If this is not your practice, then you could request the customer provide ID etc and if he did not - close the account. You would want at least minimal info on the minor, now adult individual. (you would probably only have a social for him, may not have a current address, would not have his signature on file and would not have a driver's license/state ID number on file)

Banks not wanting to CIP each new account are looking for ways to indicate on the system which has been CIP'd. This question would prompt the need to indicate who was CIP'd and allow the CSR to get a new ID some years later, if you were required to check that customer.

This is a hole but I agree that CIP doesn't require it and it is a hole of minimal risk. Add that CIP doesn't replace KYC/EDD and you should still be weary of transaction changes that would call alarm to the account later on.

I think you would have to do the CIP routine when the minor=>major customer opens the new account unless you have already formed a reasonable belief as to his/her identity. You didn't do that when you opened the minor's account, you IDd the parent. Just turning 18 would not trigger this but the opening of a new account COULD (unless you have that reasonable belief, etc.)

I think you can easily call the minor/now adult an existing customer if you have had an account with them for some time. You have been sending statements to them. Contacting a customer is a type of non-documentary verification. That would satisfy it in most cases.