You HAD a customer who rescinded. You had CIP duties and presumably completed them. You are required by FinCEN regulations to retain the identifying information about the customer (Name, DOB, Address at the time, SSN or other ID number) for five years after the account is closed. You also have to retain for five years after the record is made, the description of the document(s) relied on for verification of the customer's identity, a description of the methods and results of any measures taken to verify identity using non-documentary or other methods, and a description of the reslution of any substanative discrepancy discovered when verifying the ID information.
See FinCEN's CIP regulation at 31 CFR 1020.220(a)(3)
The recordkeeping requirement doesn't evaporate with the customer's rescission.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8