We have had several loan applications that have ended up being denied or withdrawn that never had a CIP form completed. Does anyone know of a fool-proof way to make sure the CIP form is obtained? Also, if a CIP form is not completed and the officer submits a "MEMO" stating that the CIP Form was not obtained and will not ever be able to be obtained, will we be written up by examiners?

It's my understanding that you only have to do CIP when you establish a relationship with the entity. When you deny the loan or it's withdrawn, there is no relationship and CIP isn't required.

From the OCC FAQ:
"Customer" does not include a person who does not receive banking services, such as a person whose loan application is denied.

Thank you so much for your input.

That is true that they would not be a "customer", but if your procedures require that certain CIP information should be obtained before the credit decision is made, and this is evidenced as not being done, it may look like you are not following your own procedures.

Cheryl,

My concern would be if they were taking the same approach and not collecting government monitoring information (where and if applicable).