In regards to subsequent account openings and using the previous form, we will be getting the customer to sign a short form stating all information on the previous form is current and up to date.

My question is, if the beneficial owners are the same, but their information has changed, i.e. name due to marriage or identification is expired, can we still use the short form because the ownership is the same and just get an updated copy of the drivers license for the beneficial owner whose information needs to be updated? FAQ #16 seems to apply in this situation by referencing an example of an address change,but it doesn't specifically reference a triggering event such as a new account being opened, just that we do not have to get a new certification form to update customer information as part of our ongoing risk based monitoring procedures.

Can someone clarify whether this applies to subsequent account openings and that a new certification form is not necessary?