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#2251561 - 03/31/21 03:49 PM Updating Expired IDs
Community Banker Offline
Member
Joined: Nov 2008
Posts: 64
I’ve been out of BSA for a while but it looks like I’m tiptoeing back in it. I’ve been presented with a situation where previous officer required staff to update all expired ID information because of ‘bsa regulations’. What I remember is that we are required to get CIP information at account opening for new customers. But there is no regulatory requirement to get updated information.

Now, I am on the bandwagon as someone that recognizes all of the benefit for getting this done - but it is done as a business decision of the bank (policy and procedure) versus a requirement of BSA. Correct? Or have I forgotten everything I thought I knew? Thanks for your help!

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#2251564 - 03/31/21 04:04 PM Re: Updating Expired IDs Community Banker
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 3,961
New York City
If you identify me at account opening and you're reasonably certain that I'm ACB just because my DL expires I don't stop being ACB. We had this debate with the FDIC and once it was escalated, they agreed that we can update expired IDs in the normal course of business.
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#2251636 - 03/31/21 08:09 PM Re: Updating Expired IDs Community Banker
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,336
Cape Cod
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.
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#2251655 - 03/31/21 09:02 PM Re: Updating Expired IDs Community Banker
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,714
You are here
While it is good to update the ID expiration dates. I am not sure how an expiration date on the signature cards or system will identify the customer (if the Drivers license is used). One would still need to see the drivers license i(f that document is used) to ID the customer and they date would be there.

If the bank is using another document to ID the customer why would they put the drivers license number on the CTR?
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#2251675 - 04/01/21 03:43 PM Re: Updating Expired IDs Community Banker
Community Banker Offline
Member
Joined: Nov 2008
Posts: 64
Thanks for all of your comments!

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