Are you citing exceptions when the customer fails to date your beneficial ownership certification form? Is the expectation that the customer will return to date the form, or are you documenting in some other way that the certification was obtained at account opening (a memo to file)?

Seems like a pretty easy "apparent violation" to cite if you cant prove when the certification was obtained. Trying to get an idea of what others are doing to address the date missing issue.

Thanks!

You don't have a received stamp that you use on any other document from a customer that is time sensitive and may not be dated by the customer?

I don't see this as a big deal. Just write the date in and make a notation that customer forgot to provide the date and initial it.

Or do what Randy said.