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?