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#1980852 - 12/03/14 10:53 PM Closing of Accounts
LizzyP Offline
Junior Member
Joined: Jul 2006
Posts: 48
What is an appropriate time frame to close accounts that have failed to produce all required documents? I cannot find where there is a specific time frame to gather documentation for "Know your Customer" other than a reasonable time before closing an account. We have 30 days in our policy but new management is questioning this.
Confused most of the time!

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#1980854 - 12/03/14 10:57 PM Re: Closing of Accounts LizzyP
rlcarey Offline
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Joined: Jul 2001
Posts: 79,893
Galveston, TX
Well, most banks don't open them to begin with and only have to deal with this if an exception is noted after the fact. I think the more common timeframe is they call the customer and give them 10 days to produce what is needed or to come in and close the account or the bank sends them a check for their balance.
The opinions expressed here should not be construed to be those of my employer:

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#1980879 - 12/04/14 12:11 PM Re: Closing of Accounts LizzyP
Pat Patriot Act Offline
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Pat Patriot Act
Joined: Apr 2009
Posts: 450
If the customer satisfies CIP and the account is technically "open" on the core, it would be prudent to put a freeze on the account until the remaining CDD documentation is provided. Thirty days is reasonable for your policy, but in practice, rlCarey's deadline is spot on.

Be careful not to change your policy to require a standard you cannot meet.

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#1980893 - 12/04/14 02:00 PM Re: Closing of Accounts LizzyP
ACBbank Offline
Power Poster
Joined: Jul 2006
Posts: 4,210
New York City
We won't open an individual account unless someone has the appropriate ID with them. We sometimes have issues with corporate accounts, specifically LLCs. We will open the account with the Certificate of Formation and then give them 30 days to produce the Operating Agreement.
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#1980917 - 12/04/14 02:47 PM Re: Closing of Accounts LizzyP
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,785
Cape Cod
For personal accounts, a much shorter waiting period might be appropriate if you're waiting for an ID document or TIN. The individual either has the ID documents/TIN or not, and it shouldn't take 30 days to get a new TIN if one is needed. If it were my decision to make, the account would not be opened until the CIP process has been completed.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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