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#2082086 - 06/06/16 09:48 PM CIP Record Retention
Diana Timberlake Offline
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We do not retain paper CIP records. We enter the information in our system where it is retained. We also try to obtain updated information on our customers when possible, which would include an updated Driver's License/updated expiration date, etc. If we overwrite the original driver's license information such as expiration date, would that be in violation of retaining the original CIP info. Also, we are considering applying CIP to existing customers if they open a new account. Again, since we are retaining this information on our system, we would be overwriting the original DL exp. date, etc.

I am interested in hearing how other banks are able to retain the info on their system and not a paper form (even though the paper will be imaged).

When I think about it, if we do an address change, we are writing over the original address that we obtained when we applied the CIP Process.

I am looking for input and assistance. Thanks in advance.

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#2082090 - 06/06/16 10:09 PM Re: CIP Record Retention Diana Timberlake
Doug Hendrickson Offline
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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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#2082145 - 06/07/16 02:05 PM Re: CIP Record Retention Diana Timberlake
John Burnett Online
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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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#2082148 - 06/07/16 02:09 PM Re: CIP Record Retention Diana Timberlake
Kathleen O. Blanchard Offline

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Is your information actually overwritten? When I was doing BSA audits, I found that most systems archived that original CIP information and it was retained in accordance with the CIP requirements. In the current record, the data was overwritten, but not in the archive.

How have you passed BSA audits if you could not demonstrate how your CIP was saved?
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#2082150 - 06/07/16 02:14 PM Re: CIP Record Retention Kathleen O. Blanchard
Doug Hendrickson Offline
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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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#2082158 - 06/07/16 02:41 PM Re: CIP Record Retention Diana Timberlake
rlcarey Offline
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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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#2082171 - 06/07/16 02:55 PM Re: CIP Record Retention Diana Timberlake
Doug Hendrickson Offline
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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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#2082175 - 06/07/16 03:03 PM Re: CIP Record Retention Diana Timberlake
Kathleen O. Blanchard Offline

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I would discuss cip retention with the vendor. Also, when a bank moves to a new vendor there are/need to be processes to hand off and retain all existing cIp data.
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#2082184 - 06/07/16 03:21 PM Re: CIP Record Retention Diana Timberlake
Doug Hendrickson Offline
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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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#2082187 - 06/07/16 03:25 PM Re: CIP Record Retention Doug Hendrickson
Elwood P. Dowd Offline
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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
BowlingQueen Offline
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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! smile
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#2082310 - 06/07/16 07:20 PM Re: CIP Record Retention BowlingQueen
Doug Hendrickson Offline
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Thanks! Hopefully once we convert we'll stick with Fiserv and not switch yet again!!!!!!!!!!!!
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#2082373 - 06/07/16 09:58 PM Re: CIP Record Retention Diana Timberlake
ItNeverEnds CRCM Offline
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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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#2082377 - 06/08/16 02:31 AM Re: CIP Record Retention Diana Timberlake
Kathleen O. Blanchard Offline

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No you are not the only one. I do know banks that scan documents but the actual rule says to describe...and that information is automatically saved by their systems. In many cases, they want these documents (corporate or llc formation docs, etc. for multiple reasons.)

Hard copy can be scary for CIP...how do you retain "forever" until after they are gone...it needs to be protected.
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