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#223555 - 08/04/04 04:26 PM Re-CIP closed account
LSmith Offline
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LSmith
Joined: Dec 2002
Posts: 703
When an account goes to zero (Assuming this is the ONLY account customer has), it goes to a "CLOSED" status" after 30 days, but the account number is actually still on our computer system for two years. If a customer still had a deposit slip a year later, and came in, made a deposit using that deposit slip (maybe put through ATM), no one would know until the next morning when the deposit rejected. Operations would change the status to "active" and make the deposit. In this case are we still obligated to re-CIP this customer? The account is effectively opened, but we would have to re-cip after the fact. If the customer was originally CIP when the relationship was established, would it still suffice if the customer made a deposit to a closed deposit account.

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#223556 - 08/04/04 07:18 PM Re: Re-CIP closed account
Cathy P Offline
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Cathy P
Joined: Jan 2003
Posts: 318
NE
You will want to check your bank's CIP Program to see what it says about this situation.

According to our policy, we would have to do CIP on them again because they don't have another account that is still open and active with us.

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#223557 - 08/04/04 07:45 PM Re: Re-CIP closed account
Andy_Z Offline
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Andy_Z
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Quote:

When an account goes to zero (Assuming this is the ONLY account customer has), it goes to a "CLOSED" status" after 30 days, but the account number is actually still on our computer system for two years. If a customer still had a deposit slip a year later, and came in, made a deposit using that deposit slip (maybe put through ATM), no one would know until the next morning when the deposit rejected. Operations would change the status to "active" and make the deposit. In this case are we still obligated to re-CIP this customer? The account is effectively opened, but we would have to re-cip after the fact. If the customer was originally CIP when the relationship was established, would it still suffice if the customer made a deposit to a closed deposit account.




A - I think you are trying to redefine a "closed" account and a "dormant" account. Absent state laws, this is your choice.

B - From the bolded comments, I believe you see this as "closed".

C - If there is no existing relationship when the new account is opened, CIP should be done.
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#223558 - 08/04/04 09:53 PM Re: Re-CIP closed account
Compliance Mom Offline
Junior Member
Joined: Apr 2003
Posts: 45
Tennessee
It seems to me that if only 2 years have elapsed, you should still have the customer's original CIP file somewhere and could just verify that the info is current and correct. Our policy is to do this and since we are currently using the paper system, we only make new copies if the old ID has expired or vital info such as address has changed.

Fortunately, we'll being going completely electronic this fall.
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