I am trying to update our BSA policy and need to address how ways we could do CIP for elderly or disabled individuals that possibly may not be able to come into the bank, etc. I was wondering if I could get some input from other banks as to how they would handle these situations as far as CIP goes.

I sent you a PM

I'm very interested in that too! (not as) could you share that wth me? Thank you!!

Why not share with everyone? Others would like to know as well...

I don't see why I can't share

As with anything regarding CIP ... you need to document in your policy what you allow (documentary and non documentary).

• NOTE: Consistent with the provisions outlined in the Bank’s BSA Policy, special consideration may be allowed for certain elderly or disabled persons that may not possess identification documents that would normally be considered acceptable by the Bank. Therefore, and only if no other form of acceptable identification is available, the Bank may accept as appropriate identification, a social security, Medicare, Medicaid or other insurance card, along with another document that contains both the name and address of the individual (e.g.: an organization membership or voter registration card, utility or real estate bill). These documents will be accepted only if the Bank is confident that the elderly or disabled person is who he/she says he/she is.