We have been doing a CIP lookback of all clients. At this time we have several accounts that we have been unable to get the client to provide us with the information we believe is necessary to adequately indentify the client. My bank would now like to play hardball and "freezes" the accounts (allow no debit no credit)until we have all information on hand - obviously we will need to let the client know we are going to do this - I'm wondering if we need to give 30 day notice - due to adverse affect on the account? Are there other regs that I should be looking at for direction other than Reg DD?

Thanks.

At my bank, if it is identification information that is missing (driver's license or whatever) then we send a series of letters, with copies to the branch, and eventually close the account if we do not receive what we need. If we are missing the required information (name, address, TIN), then we immediately freeze the account and send both a notice to the customer and call the branch to get in touch with the customer. We do this because our interpretation is that we should not be doing business with someone who has not provided the required information. That usually gets fast results. We did not send advance notice as we do provide the required CIP notice that the information is required. So far, we have not been criticized.