Community Banker, you're memory isn't failing you, and the rules haven't changed with respect to CIP. When my driver's license expires in 2024, my identity doesn't change, and CIP regs don't allow you to change the original information gathered to verify my identity when I opened my account. But you can ask for updated information when the license expires for your business purposes, which might include completion of a CTR if I am ever blessed with a reportable amount of cash or for ID info when I cash a check, etc.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8