We are still revisiting our CIP Program. Sometimes you learn new things when you re-read a reg that has been ni place over 10 years!...
We do not see where banks would be expected to have a one stop record of identification info. The reg just says "record of info obtained at account opening".
In the past we used a database format to house the details required.
With a new core system, the system creates a snapshot report of info input at the time an account is created. There are times when the ID information used for verification (for example, D. LICs., or articles of incorporation for a business) were not handy at the time the account was created. We obtained them, in most cases, the next day. That is too late for the snapshot report. So, we have "records" on hand rather than one record. If the Feds asked to have the records for an account opened, we would produce the report was well as screen prints of the docs. used. If people wanted to be picky, we would go to our maintenance report to determine when the ID verification docs were added to the account screen.
All this being said, we think we are OK with not having the snapshot report being the drop dead record needed for CIP. The report is one piece.
We would like to know if other banks are using:
1. one report showing everything or
2. A system such as the one we described.

We have a CIP archival report which is automatically produced weekly but has a one month lag. For example, the report produced 12/18/16 would generally have the customer CIP records for new customers opened from 11/12/16 to 11/18/16.

I would imagine the one month lag is to help capture instances where CIP documentary verification information was not entered immediately or maybe had some clerical corrections shortly after opening.

Additionally, there is functionality to run a report for CIP retrieval for specified criteria, where it pulls the data from the archived CIP data (the data noted in the weekly report)...for example, this would be useful if you want one report showing all the records for new customers from an entire year. You can run the retrieval report for that time frame instead of looking at 52 individual weekly reports.