Thread Options
|
#2204233 - 01/29/19 02:16 PM
CIP Expired DL
|
Member
Joined: Jul 2016
Posts: 61
|
If your customer already has an account at the bank and they open another one years later, and the ID is expired should we require an updated ID even if we know that is the person opening the account?
|
Return to Top
|
|
|
|
#2204234 - 01/29/19 02:20 PM
Re: CIP Expired DL
PegH
|
100 Club
Joined: May 2018
Posts: 232
|
I would instruct the branch staff to get an updated ID. Yes.
|
Return to Top
|
|
|
|
#2204263 - 01/29/19 04:21 PM
Re: CIP Expired DL
PegH
|
Member
Joined: Aug 2004
Posts: 79
Any where but work
|
You really should read your CIP policy and/or procedures, to see what your financial institutions expectations are. I believe that per the regulation governing CIP, the identification procedure is a one time and your in, as long as customer has open accounts there is no need to update information. If the individual has closed all accounts and comes back to open a new relationship then yes you need to redo CIP identification procedures. Correct me if I am wrong, please.
|
Return to Top
|
|
|
|
#2204264 - 01/29/19 04:31 PM
Re: CIP Expired DL
PegH
|
Platinum Poster
Joined: Apr 2014
Posts: 673
|
one deer, that is the way I understand it also, we are not required, but if they have it we try and get it updated in the system.
_________________________
Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney
|
Return to Top
|
|
|
|
#2204283 - 01/29/19 05:39 PM
Re: CIP Expired DL
PegH
|
Power Poster
Joined: Jul 2006
Posts: 4,344
New York City
|
A person's identity doesn't change because a document expired. I'm still ACB whether my identification document is valid or not. Get a new copy of the document according to your procedural requirements.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu
|
Return to Top
|
|
|
|
#2204334 - 01/29/19 08:39 PM
Re: CIP Expired DL
PegH
|
Diamond Poster
Joined: Apr 2013
Posts: 2,199
The West
|
If you are obtaining it, then it is for reasons other than CIP. It's just not required. CIP is a one and done matter. You identify the customer to form a reasonable belief when the relationship is entered into. The fact that their license has expired doesn't change anything.
_________________________
TryingToComply CRCM
|
Return to Top
|
|
|
|
#2204357 - 01/29/19 09:58 PM
Re: CIP Expired DL
ACBbank
|
Power Poster
Joined: Jul 2008
Posts: 4,796
You are here
|
A person's identity doesn't change because a document expired. I'm still ACB whether my identification document is valid or not. Get a new copy of the document according to your procedural requirements. if you are trying to match the picture ID up to the individual a 18 year old may not look like a 90 year old eventhough you are the same. (expired for a short period vs long period) Id's are lost, stolen and altered all the time hence the reasoning for policy to include un-expired. Some of our older ids (in NYS) did not have pictures on state issued Id's when first issued. You need to follow whatever you bank policy is.
_________________________
Opinions can be considered as coming from anywhere but my employer.
CAMS
|
Return to Top
|
|
|
|
#2204395 - 01/30/19 02:00 PM
Re: CIP Expired DL
PegH
|
Power Poster
Joined: Jul 2006
Posts: 4,344
New York City
|
If you're a big bank with hundreds of thousands or millions of customers (Or a small bank with a limited staff), operationalizing updating ID's is a nightmare. Different states have different formats and don't even get me started on passports. I stand by my original comment. Whether I'm 18 or 90, I'm still ACB and you can update IDs during the normal course of business.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu
|
Return to Top
|
|
|
|
#2209219 - 03/21/19 06:43 PM
Re: CIP Expired DL
PegH
|
New Poster
Joined: Mar 2019
Posts: 1
|
Not that this pertains entirely to an expired drivers license.. What is or should be the procedure for a name change? A marriage Certificate, new DL.. Should this person be ran through the system again as a new customer? What are the BSA rules for this?
|
Return to Top
|
|
|
|
#2209294 - 03/22/19 04:51 PM
Re: CIP Expired DL
PegH
|
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
|
Hello Sarah and welcome to BOL! Just like any change you will need supporting documentation. A marriage certificate is good, we usually request that they update their drivers license or other State ID prior to us making the change but it is not a requirement. No need to run them through the system again since they are not a new customer.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him. -David Brinkley
|
Return to Top
|
|
|
|
#2209408 - 03/25/19 05:44 PM
Re: CIP Expired DL
PegH
|
10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
|
Agreed. A change of name does not mean a change of identity. He or she is the same individual as before the name change. Some, if not many, banks would also require evidence the name change had been made with the Social Security Administration, too, especially if there is an interest-earning account involved.
_________________________
John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
|
Return to Top
|
|
|
|
#2217771 - 07/16/19 07:49 PM
Re: CIP Expired DL
PegH
|
Gold Star
Joined: Aug 2018
Posts: 348
|
Thoughts on an existing customer (individual) opening a business account, XYZ LLC, and having an expired DL on her for Beneficial Ownership purposes? Shouldn't we have collected a new DL for her individually? Front line giving me some push back.
|
Return to Top
|
|
|
|
#2217776 - 07/16/19 08:17 PM
Re: CIP Expired DL
PegH
|
Gold Star
Joined: Mar 2018
Posts: 338
|
According to question 7 in the second FAQ you can rely on CIP information you've previously obtained as BO verification. Of course your P&P would have to allow for this.
|
Return to Top
|
|
|
|
#2217818 - 07/17/19 02:28 PM
Re: CIP Expired DL
PegH
|
New Poster
Joined: Feb 2017
Posts: 7
|
From FAQ 7: "...a financial institution may rely on information in its possession to fulfill the identification and verification requirements, provided the existing information is up-to-date, accurate, and the legal entity customer’s representative certifies..."
For me this means that if you have an expired DL for a ben owner, you need to get a current one when you open a new account.
|
Return to Top
|
|
|
|
#2217820 - 07/17/19 02:31 PM
Re: CIP Expired DL
PegH
|
Gold Star
Joined: Aug 2018
Posts: 348
|
|
Return to Top
|
|
|
|
#2217904 - 07/17/19 10:26 PM
Re: CIP Expired DL
PegH
|
Gold Star
Joined: Mar 2018
Posts: 338
|
For what it’s worth (not much) my interpretation of that sentence is different. “Existing information,†in my opinion, refers to CIP information (name, dob, address, TIN) and not to CIP verification information (ID). I also think that for all practical purposes, as described above, their identity hasn’t changed because their ID expired, and the purpose of this is to identify beneficial owners. My examiner had no issues with this, but your mileage may vary.
|
Return to Top
|
|
|
|
|
|