We have a customer that recently moved and is refusing to provide us with her new residential address. Additionally, her mailing address is a business. We want to close the account since there are several red flgas (she is quite combative about the address issue). Can we close the account for lack of CIP information? Should we state the citation from the Reg stating that we have to have a residential address on file?

I'm sure your depositor's agreement allows you to close the account at any time for any reason. Close the account, you don't need to provide a reason.

The account should have never been opened to begin with - do some training.

Wow! How did you get that from the limited information given? Perhaps this account is already established and a residential address was obtained at account opening. Also, that was pretty rude.

While after re-reading the post, I do see where this was an existing customer and not a new one - so sorry if it came across rude. However, there is no reason to do business with uncooperative customers. Customers refusing to provide basic information to the bank, such as current address should be jettisoned from the bank pronto. It is usually a sign of a tip of the iceberg for future problems.

The regulation states that you have to obtain the physical address at the time the account is opened. There is no ongoing requirement in CIP to continue to obtain updated addresses. So this isn't a CIP issue.

That said, your internal policies may require the customer to provide you with any updates to their physical address. And your disclosure likely gives you the right to close the account. So if the custoemr is causing you to be in violation of your own policies, than I'd recommend terminating the relationship.

I agree 100%. I constantly have to remind customers that banking with us is not a right. It's an agreement that has certain conditions both parties must live up too.

Thank you very much to all! I appreciate your responses.