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#2082090 - 06/06/16 10:09 PM
Re: CIP Record Retention
Diana Timberlake
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Power Poster
Joined: Oct 2009
Posts: 3,927
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We keep the paper and image it. This allows us to retain both the minimum identifying information and the "...description of the methods and results used to verify the identity of customers..." for the applicable time periods (in reality, both are kept for 5 years after the account is closed).
For us, this is the only way of maintaining this information; otherwise if we update the information on the system we overwrite what was there which I believe would violate the regulation. It would be nice if our system had the ability to retain that information electronically at account inception and place it somewhere that it couldn't be updated while we could update customer information as circumstances warrant.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#2082145 - 06/07/16 02:05 PM
Re: CIP Record Retention
Diana Timberlake
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10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
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I agree that overwriting the original CIP information is a violation. The rule requires you retain that information, not that you maintain it (as in updating it).
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#2082150 - 06/07/16 02:14 PM
Re: CIP Record Retention
Kathleen O. Blanchard
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Power Poster
Joined: Oct 2009
Posts: 3,927
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I've looked and see no 'archive' of the original information on our current core processor. As far as audits, we demonstrate that the CIP was saved because we keep the image of the original CIP completed at account opening.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#2082158 - 06/07/16 02:41 PM
Re: CIP Record Retention
Diana Timberlake
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10K Club
Joined: Jul 2001
Posts: 83,363
Galveston, TX
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Doug,
Your system must create a maintenance record of the original CIF set-up for the customer on the date of creation? Otherwise, how does anyone proof the creation of the record back to the original documents? Any changes to the information would be reflected in your on-going maintenance records.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#2082171 - 06/07/16 02:55 PM
Re: CIP Record Retention
Diana Timberlake
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Power Poster
Joined: Oct 2009
Posts: 3,927
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As far as I can tell (D+H SPARAK) does keep a log of account changes for each account. However, nothing is logged when the account is first created except the fact that it was new on creation date. After that, if we change the address you can see the address change logged (with old/new). We have a 'next-day' procedure whereby one person checks the work of another to ensure that what is on the system matches to the original documents. And since we converted from another system almost 5 years ago, you won't see the history of changes back further than that time period.
I'm not sure how it's going to work in Fiserv Precision, but if anyone has any experience I'd like to hear it.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#2082184 - 06/07/16 03:21 PM
Re: CIP Record Retention
Diana Timberlake
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Power Poster
Joined: Oct 2009
Posts: 3,927
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Since we image all CIP and have kept them there hasn't bee a perceived need to discuss CIP retention with the vendor. We will port those images to the new vendor and also ask how they maintain CIP information.
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I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#2082187 - 06/07/16 03:25 PM
Re: CIP Record Retention
Doug Hendrickson
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10K Club
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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Good issue to resolve now... As it reads, the CDD regulation will require banks to perform CIP on the beneficial owners each time the legal entity opens a new account and retain the information for each specific instance.
"Overwriting" will not work.
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#2082290 - 06/07/16 06:44 PM
Re: CIP Record Retention
Diana Timberlake
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Power Poster
Joined: Mar 2007
Posts: 2,920
Wisconsin
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We have reports available in the Fiserv Director system that holds years and years of information, including CIS/CIF reports that contain CIP information inputted into the system at account opening. So, even though we do update customer information, including dates on renewed IDs, we can go back and find the original CIP information collected electronically. Even with that, we still print the "application" that also contains this information and retain it for 5 years. Hope that helps!
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#2082310 - 06/07/16 07:20 PM
Re: CIP Record Retention
BowlingQueen
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Power Poster
Joined: Oct 2009
Posts: 3,927
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Thanks! Hopefully once we convert we'll stick with Fiserv and not switch yet again!!!!!!!!!!!!
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I hear and I forget. I see and I remember. I do and I understand.--Confucius
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#2082373 - 06/07/16 09:58 PM
Re: CIP Record Retention
Diana Timberlake
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Platinum Poster
Joined: Oct 2006
Posts: 995
Looking for my sanity
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This is probably a stupid question, but I've read a few of these discussions and I wonder if I'm the only one who maintains CIP info on the signature card (at least for consumers)? Either hard copy or scanned/electronic copy. Maybe I'm just old fashioned, but it just seems easier to retain the information on the signature card vs. creating a separate document or trying to maintain it on a CIF that can be overwritten or modified.
Am I the only one who does this?
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