We are making the following changes to our application forms to comply with CIP. Did we miss anything? Are the examiners citing violations if you miss any of these items?
1) Changed "age" to "date of birth"
2) Added "SSN/TIN"
3) Added CIP notice

You appear to be a little late on CIP......scary considering that this regulation will probably be the regulators hot topic this year.

The regulation makes it clear that the bank must obtain the Fab 4 pieces of information (three for non-individuals). If the bank fails to obtain these pieces of information, I'm sure you will be cited.

There are other requirements (capturing expiration and issuance dates)if you are accepting government issued identification. And you should have procedures for documenting discrepancies and non-documentary methods that were used.

Good luck!