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#1617224 - 10/18/11 09:07 PM CIP for an Existing customer
Cedar Point Guy Offline
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Cedar Point Guy
Joined: Nov 2009
Posts: 732
Cedar Point
Hi All,

We are having a discussion here and I need some imput on the matter. If we have an existing customer and they call for any type of service on their account (getting account balance, ordering a debit card, things along these lines) does CIP come into play? Or is CIP only for account openings? Can anyone point me to something that states what information needs to be obtained for existing customers.
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#1617257 - 10/18/11 09:57 PM Re: CIP for an Existing customer Cedar Point Guy
Here4Life Offline
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Posts: 121
You always want to verify who you are speaking with before any information is given. As far as, the US Patriot Act, I believe existing customers prior to July(?) 2003 are exempt from those procedures. However, if the customer closes his/her accounts & then opens a new one sometime later, then yes US Patriot Act applies.

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#1617280 - 10/18/11 10:49 PM Re: CIP for an Existing customer Here4Life
pweiss Offline
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Joined: Mar 2011
Posts: 103
CA
I would definitely verify your customer, regardless of when they opened up their account, when they request a new card, change address, etc. Balances is another big one too. I have heard story after story of tellers and CSR giving balances to the wrong person and the actual account holders comes in and causes a huge stir (rightfully so). This happens a lot with ex-spouses when it comes to child support or employees that handle bookkeeping.

I know address changes are looked at during exams so you should have ID documentation.
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#1617313 - 10/19/11 10:14 AM Re: CIP for an Existing customer Cedar Point Guy
Elwood P. Dowd Offline
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Next to Harvey
Information gathering for CIP takes place "prior to opening the account." CIP verification takes place within "a reasonable time after the account is opened." 1020.220(a) Per the Q & A, it can also take place when signatories are added during the life of the account. It has no bearing on the circumstances you list.

Existing customers are not exempt unless your CIP explicitly spells that out.
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#1617322 - 10/19/11 12:32 PM Re: CIP for an Existing customer Elwood P. Dowd
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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For transactions or responding to requests for information, the bank is not conducting CIP on the customer (as Ken stated that takes place prior to opening the account), but is authenticating the customer to ensure you are dealing with the actual customer.

For authentication, you should follow bank policy to obtain sufficient information to know you are actually dealing with your customer. The FFIEC authentication guidance will help with this if your bank needs to establish standards for this.
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