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#2231174 - 02/18/20 05:00 PM CIP question - I know . . . Really?
Madawaska Offline
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Joined: Sep 2008
Posts: 105
VA
I can't believe I'm asking this but here goes . . .

Is it absolutely required that if the ID document collected contains an Issue Date, that the issue date must be recorded and retained?

If CIP is risk based, and we retain the ID document type, ID number, and expiration date, isn't that acceptable?

Our core system is limited and the ID issue date is only visible at account opening and thereafter is not viewable.

I'm trying to eliminate a paper form that is used to document the issue date. I don't see the risk or the value in this particular element.

Thanks for your input. It is much appreciated.

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#2231178 - 02/18/20 05:32 PM Re: CIP question - I know . . . Really? Madawaska
Big Dog Offline
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There is no regulatory requirement to capture the issue date, but your policy or procedures may require it. If that is the case, follow your procedures, or change/update with proper approvals
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#2231181 - 02/18/20 05:39 PM Re: CIP question - I know . . . Really? Madawaska
rlcarey Online
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Galveston, TX
I think you need to check the regulation:

(3) Recordkeeping. The CIP must include procedures for making and maintaining a record of all information obtained under the procedures implementing paragraph (a) of this section.

(i) Required records. At a minimum, the record must include:

(B) A description of any document that was relied on under paragraph (a)(2)(ii)(A) of this section noting the type of document, any identification number contained in the document, the place of issuance and, if any, the date of issuance and expiration date;
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#2231184 - 02/18/20 05:55 PM Re: CIP question - I know . . . Really? rlcarey
Madawaska Offline
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Joined: Sep 2008
Posts: 105
VA
Yes, I've seen this in the regulation.

So I guess I'm bound to the paper form just to document an issue date that provides no value in identifying a customer.

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#2231259 - 02/19/20 03:18 PM Re: CIP question - I know . . . Really? Madawaska
ColoradoAML Online
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Posts: 273
This isn't to say that I'd oppose eliminating that requirement, but the issue and expiration date help to demonstrate the validity of the document just like the ID number do, so I'm not really sure what you mean that it has no value. When I look at the ID of someone I've never met, the issue and expiration date may give me more confidence about who they are then the ID number necessarily would.

CIP isn't about how you're identifying a customer when they return to the bank after they've opened an account, it's about collecting information to demonstrate that they've identified themselves to you and you've reasonably verified that what they told you is true.

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