I have read so much about CIP(confusion in process) I am definately confused. What is the penalty if we fail to obtain the 4 required pieces of info on a particular transaction(name-address-date of birth-id#)? Our procedures are to copy the DL and document the SSN, but we had a CSR open an account yesterday and forgot to get it. Let's assume we call the customer and/or write a letter requesting the info, but they fail to provide it do we have to close the account?

Now let's assume we call and they fax us the info. It is obviously after we opened the account and they may have used the account could a penalty be assessed?

I have not read or seen anywhere in literature about the penalties they intend to assess or what type of penalties they will be. If anyone else has seen anything, I would be curious to know also. As far as verifying the information after the account has been opened, what did you state in your policy. If you stated that you could have a period of time to verify the identity, you could restrict the account until you received the verification and document that in the file when you eventually receive the verification. I would handle the situation in the manner that you wrote your policy.

I believe recordkeeping violations are $500 a pop (if assessed).