Thread Options
#2081245 - 06/01/16 01:43 PM CIP record retention
complynewbie13 Offline
100 Club
Joined: Dec 2014
Posts: 146
Minnesota
Customer opens an account and we CIP them. The customer moves and closes their account. The customer comes back a year later and now since they are a new "customer" we CIP them again. Can we purge the "old" CIP info, or do we have keep this since the retention is 5 years after the account closes. Currently, with our filing system, we CIP them, then never remove the CIP file.... Since this is our filing system, we in this case have 2 CIP files. Can we purge the old one and replace it with the new CIP info?

Return to Top
BSA/AML/CIP/OFAC Forum
#2081261 - 06/01/16 02:15 PM Re: CIP record retention complynewbie13
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,336
Cape Cod
No. Each CIP record stands on its own, and has to be retained until five years after the customer's account(s) are closed. So you will have two CIP records for that customer until five years after the first account closed.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2081264 - 06/01/16 02:16 PM Re: CIP record retention complynewbie13
complynewbie13 Offline
100 Club
Joined: Dec 2014
Posts: 146
Minnesota
Thank you.

Return to Top

Moderator:  Andy_Z