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#2204233 - 01/29/19 02:16 PM CIP Expired DL
PegH Offline
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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?

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#2204234 - 01/29/19 02:20 PM Re: CIP Expired DL PegH
SmallBankBSA Offline
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I would instruct the branch staff to get an updated ID. Yes.

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#2204263 - 01/29/19 04:21 PM Re: CIP Expired DL PegH
one deer Offline
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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.

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#2204264 - 01/29/19 04:31 PM Re: CIP Expired DL PegH
Sunshine Lady Offline
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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.
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#2204283 - 01/29/19 05:39 PM Re: CIP Expired DL PegH
ACBbank Offline
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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.
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#2204334 - 01/29/19 08:39 PM Re: CIP Expired DL PegH
TryingtoComply Offline
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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.
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#2204357 - 01/29/19 09:58 PM Re: CIP Expired DL ACBbank
edAudit Offline
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Originally Posted By ACBbank
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.
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#2204395 - 01/30/19 02:00 PM Re: CIP Expired DL PegH
ACBbank Offline
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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.
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#2209219 - 03/21/19 06:43 PM Re: CIP Expired DL PegH
Sarah Graham Offline
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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?

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#2209294 - 03/22/19 04:51 PM Re: CIP Expired DL PegH
RockChucker, CAMS Offline
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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.
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#2209408 - 03/25/19 05:44 PM Re: CIP Expired DL PegH
John Burnett Offline
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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.
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#2217771 - 07/16/19 07:49 PM Re: CIP Expired DL PegH
praBSA Offline
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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.

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#2217776 - 07/16/19 08:17 PM Re: CIP Expired DL PegH
ColoradoAML Offline
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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.

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#2217818 - 07/17/19 02:28 PM Re: CIP Expired DL PegH
mleu Offline
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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.

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#2217820 - 07/17/19 02:31 PM Re: CIP Expired DL PegH
praBSA Offline
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Posts: 281
Thanks for the citation.

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#2217904 - 07/17/19 10:26 PM Re: CIP Expired DL PegH
ColoradoAML Offline
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Posts: 241
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.

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